BSA/AML Officer & Blockchain Compliance

Bullish•New York, NY

2d•$175,000 - $215,000•Onsite

About The Position

Bullish is seeking a BSA/AML Officer with deep blockchain compliance expertise to support the expansion of its regulated U.S. digital currency trading business, including spot, derivatives, and tokenized securities activities across its MTL, FCM, and Broker Dealer entities. The role is responsible for Bullish’s BSA/AML and OFAC sanctions programs and for maintaining compliance with applicable local, U.S., and international laws and regulations affecting the digital currency industry. It also applies specialized knowledge of blockchain structures, networks, and on-chain activity to develop and implement suitable processes and controls. The position is based in and requires work from Bullish’s NYC office. It reports to the Chief Compliance Officer for U.S. Regulated Entities (also referred to as the U.S. Chief Compliance Officer). The officer will lead domestic BSA/AML and sanctions oversight, monitoring, risk assessments, regulatory reporting, recordkeeping, issue remediation, and employee training. The role also serves as the lead compliance investigator and subject-matter specialist for blockchain analytics and transaction tracing. In support of the U.S. tokenized securities business, the officer will work with Legal, Product, and Engineering to develop on-chain trading, custody, settlement, and transfer controls, and assess compliance risks associated with tokens, networks, smart contracts, and bridges.

Requirements

Experience in one or a combination of financial crime, BSA, AML, financial crime investigations, risk management, audit, or compliance, specifically with exposure to digital assets.
Experience managing regulatory examinations and relationships with examiners, auditors, and banking partners.
Extensive knowledge of the BSA, USA PATRIOT Act, OFAC regulations, and SEC, CFTC, FINRA, and NFA rules and requirements.
Awareness of applicable local and U.S. laws, international requirements, and industry standards.
Demonstrated proficiency with enterprise blockchain forensics platforms such as Chainalysis Reactor/KYT, TRM Labs, or Elliptic Forensics, including tracing complex transaction paths and producing investigative summaries.
Working knowledge of smart contract mechanics, token standards such as ERC-20, ERC-1400, and ERC-3643, and permissioned wallet registries.
Ability to assess the impact of U.S. and international securities laws on on-chain trade execution, settlement, custody, and regulatory reporting.
Strong attention to detail and strong organizational, problem-solving, analytical, and management skills.
Ability to work in a fast-paced, high-demand environment while managing multiple priorities.
Bachelor’s degree, university degree, or equivalent experience.

Nice To Haves

Advanced degree such as a JD or MBA.
Professional certification such as CAMS, CFE, CRCM, CFCS, or a related credential.

Responsibilities

Lead the compliance program for tokenized securities, derivatives, and spot crypto trading, including BSA/AML, sanctions, fraud risk, market integrity, and state licensing requirements.
Implement domestic BSA/AML and OFAC compliance programs in accordance with U.S. regulatory requirements.
Maintain risk-based BSA/AML and OFAC policies and procedures, advise staff and management of deficiencies, and ensure required changes are made.
Direct the domestic BSA/AML and OFAC compliance monitoring program and ensure adequate internal controls.
Coordinate with offshore affiliates and oversee controls they perform on behalf of U.S. entities to ensure they meet U.S. standards.
Oversee regulatory reporting to FinCEN, SEC, CFTC, FINRA, NFA, NYDFS, and other applicable regulators, including timely SAR filings.
Prepare monthly and quarterly management reports on BSA/AML metrics.
Identify, escalate, track, and remediate BSA/AML compliance issues as necessary.
Conduct BSA/AML, CIP, and OFAC risk assessments and work with stakeholders and data to inform and optimize the compliance programs.
Ensure required BSA/AML and OFAC reports are filed and related records are maintained in accordance with regulatory requirements.
Train employees on key policies, procedures, and responsibilities for preventing financial crime, and help build a firm-wide compliance culture.
Lead compliance investigations and provide subject-matter expertise in blockchain analytics, wallet clustering, and transaction tracing across spot trading, derivatives margin and settlement, and tokenized assets.
Investigate flagged deposit and withdrawal addresses using enterprise blockchain tools, tracing funds through bridges, decentralized protocols, and mixing services.
Work with Legal, Product, and Engineering to develop processes and controls for on-chain trading, custody, settlement, and transfers for the U.S. tokenized securities business.
Apply knowledge of blockchain networks, smart contracts, and tokenization structures to design and implement controls addressing emerging risks and regulatory requirements.
Develop and maintain tokenized securities compliance controls, including wallet whitelisting, investor eligibility verification, transfer restrictions, and on-chain transaction monitoring.
Assess proposed token listings, blockchain networks, smart contract upgrades, and bridge mechanisms for financial crime, sanctions, and other compliance risks.
Analyze on-chain transaction activity and smart contract data to support suspicious activity investigations, regulatory reporting, and law enforcement requests.