Brokerage and RIA CCO

ARQ•New York, NY

12d•Hybrid

About The Position

ARQ is seeking a hands-on Chief Compliance Officer to lead its US investment compliance functions, serve as CCO for its SEC-registered investment adviser, and act as the proposed CCO for its introducing broker-dealer through the FINRA New Member Application (NMA) and launch. The role oversees the RIA compliance program, supports the broker-dealer application, and builds the supervisory framework for launch. It works closely with Product, Engineering, Operations, Legal, the BSA/AML Officer, and the outsourced FINOP to embed effective controls in ARQ’s investment offering. The CCO will administer RIA compliance policies, risk assessments, monitoring, testing, and annual reviews; lead or support the FINRA NMA; develop supervisory procedures; and establish supervision for a fully disclosed introducing broker offering self-directed trading. The role also oversees compliance controls for automated, non-discretionary investment recommendations, marketing and communications, regulatory filings and registrations, conflicts and conduct, clearing and brokerage operations, books and records, privacy, customer protection, examinations, and employee training.

Requirements

10+ years of progressive securities compliance experience.
Prior service as CCO for an SEC-registered investment adviser or FINRA broker-dealer.
FINRA Series 24 qualification.
Direct experience supporting or leading a FINRA NMA, including supervisory procedures, regulatory responses, membership interviews, and preparation for launch.
Strong knowledge of the Investment Advisers Act, Securities Exchange Act, SEC adviser requirements, and FINRA rules covering supervision, communications, records, registrations, and customer protection.
Experience with fully disclosed introducing broker-dealers and clearing firms, including the division of compliance and operational responsibilities.
Hands-on experience administering RIA annual reviews, marketing reviews, conflicts controls, codes of ethics, regulatory filings, and examinations.
Experience with digital investment platforms, automated advice, and self-directed brokerage, including translating requirements into product and technology controls.
Ability to coordinate with a dedicated BSA/AML Officer and outsourced FINOP while maintaining clear ownership of the securities compliance program.
Sound judgment, strong writing, and confidence engaging regulators, challenging decisions, and explaining practical solutions to senior leadership and technical teams.

Responsibilities

Administer the RIA’s compliance policies, risk assessment, monitoring, testing, and documented annual review; maintain the compliance calendar and report material risks and remediation progress to leadership.
Help lead the FINRA New Member Application with FINRA, counsel, and internal teams; develop written supervisory procedures, prepare supporting materials, respond to information requests, participate in the membership interview, and verify readiness before launch.
Build and lead the compliance and supervisory framework for a fully disclosed introducing broker offering self-directed trading, including supervisory assignments, account and transaction reviews, testing, escalation processes, and annual reporting.
Oversee controls for automated, non-discretionary recommendations, including client questionnaires, risk profiles, portfolio methodology, algorithm testing, change management, and ongoing monitoring; maintain clear disclosures and separation from independent customer trading.
Review investment marketing, performance presentations, promotions, app content, and customer communications for SEC and FINRA compliance; maintain approval records and supervise electronic communications.
Manage Form ADV, Form CRS, Form BD, amendments, client delivery obligations, individual registrations, continuing education, advisory agreements, and customer disclosures.
Maintain the code of ethics and controls for personal trading, outside business activities, gifts and entertainment, and affiliate conflicts; oversee fiduciary-duty controls and assess custody implications, fees, and collateral arrangements.
Oversee compliance with introducing and clearing responsibilities, including account opening, order handling, applicable best execution obligations, transfers, and customer complaints; coordinate with the clearing broker and outsourced FINOP on operational controls and regulatory obligations.
Maintain compliant books and records, communications retention, privacy and safeguarding controls, and complaint handling; work with Security and Engineering on incident response and customer notification processes.
Lead SEC and FINRA examinations and inquiries, coordinate audits and remediation, and train employees.
Partner with the BSA/AML Officer on investment-related financial crime risks and document responsibilities across teams.