BSA​/AML Officer

Location: New York

About Bullish
Bullish is an institutionally focused global digital asset platform that provides market infrastructure and information services. These include:
Bullish
Exchange – a regulated and institutionally focused digital assets spot and derivatives exchange, integrating a high-performance central limit order book matching engine with automated market making to provide deep and predictable liquidity. Bullish Exchange is regulated in Germany, Hong Kong, and Gibraltar.
Coin Desk
Indices – a collection of tradable proprietary and single-asset benchmarks and indices that track the performance of digital assets for global institutions in the digital assets and traditional finance industries.
Coin Desk
Data - a broad suite of digital assets market data and analytics, providing real-time insights into prices, trends, and market dynamics.
Coin Desk
Insights – a digital asset media and events provider and operator of , a digital media platform that covers news and insights about digital assets, the underlying markets, policy, and blockchain technology.

Reports to:

Position Overview
We are seeking a BSA/AML Officer for Bullish’s regulated US digital currency trading business. In this role, you will be a key pillar in our US business expansion by leading the US Compliance program and acting as the regional BSA/AML Officer. This role supports the spot, derivative, and tokenized securities business lines in the US, encompassing the MTL businesses (spot), FCM, and Broker Dealer entities.

In this role, you will be responsible for our BSA/AML & OFAC Sanctions programs and ensuring that we maintain compliance with all applicable local, US, and international laws and regulations impacting the digital currency industry.

This position is based in NYC and will be required to work from our NYC office a minimum of 4 days per week.

Responsibilities:

• Lead the compliance program for tokenized securities, derivatives, and spot trading to meet all applicable state and federal regulatory requirements and reflect the nature of a rapidly changing risk landscape, including:

• Implement the domestic BSA/AML and OFAC compliance programs in line with U.S. regulatory requirements.

• Maintain risk-based BSA/AML and OFAC policies and procedures addressing all areas of BSA/AML and OFAC; advise Bullish staff and management of deficiencies and ensure that required changes are made.

• Direct the domestic BSA/AML and OFAC compliance monitoring program to ensure there are sufficient internal controls to promote an effective control environment.

• Coordinate with offshore affiliates and exercise oversight to ensure any controls performed on behalf of the U.S. entity by the affiliates are performed to a standard that meets U.S. requirements.

• Oversee regulatory reporting to FinCEN, SEC, CFTC, FINRA, NFA, NYDFS, and other federal and state regulators, as necessary, to comply with Bullish’s BSA/AML reporting obligations, including ensuring the timely filing of suspicious activity reports (“SARs”).

• Ensure the BSA/AML program strictly adheres to FINRA Rule 3310 (for the Broker Dealer) and NFA Compliance Rule 2-9(c) (for the FCM).

• Prepare monthly and quarterly management reporting of BSA/AML-related metrics.

• Identify, elevate, track, and remediate, as necessary, BSA/AML compliance-related issues.

• Perform BSA/AML, CIP, and OFAC risk assessments as needed and work with stakeholders and various forms of data to inform, update, streamline and optimize the BSA/AML and OFAC program.

• Lead the process for ensuring all BSA/AML and OFAC reports are filed as required and all BSA/AML and OFAC related records are maintained according to regulatory requirements.

• Contribute to building a compliance culture across the firm by training Bullish employees on key policies,…