Compliance Officer and MLRO - US (Digital Transfer Agency)

ZILO • Boston, MA

3d

About The Position

The Compliance Officer and MLRO owns compliance for ZILO’s registered transfer agent in the United States, including its Section 17A and 17Ad obligations and standing with the SEC. The role is also the designated anti-money laundering officer, with responsibility for the Bank Secrecy Act programme, customer identification programme, and suspicious activity reporting. The position sets and documents the US registrant’s compliance standards, serves as a key regulatory contact, and carries both regulatory compliance and financial crime responsibilities for the US entity. The role is expected to identify capacity constraints and escalate when workload or independence requirements indicate that a task should sit elsewhere.

The role owns the compliance position supporting investor eligibility controls enforced at the point of transaction through verifiable credentials issued and maintained by ZILO. This includes defining what each credential asserts, ensuring its conditions reflect applicable rules, withdrawing eligibility when investor status changes, and documenting the position so it can be explained to regulators and evidenced in practice.

The position reports to the COO and reports on compliance and financial crime matters to the ZILO US board and fund board. It provides second-line challenge and oversight of operational processing delivered by the UK hub for the US line, and compliance oversight of external service providers.

Requirements

• Senior compliance experience at a US SEC-registered transfer agent, fund administrator, or comparable registrant, with direct ownership of the 17Ad rule set.
• Direct experience of SEC examinations, including preparing a registrant for an examination and responding to findings.
• Prior experience as a designated AML officer under the Bank Secrecy Act, including SAR filing decisions.
• Experience owning Form TA-1 and TA-2 and the registration lifecycle.
• Experience of the annual internal accounting control study under Rule 17Ad-13.
• Judgment to form and defend a written regulatory position on a novel model, and to identify when a position is not defensible.
• Strong written communication skills, including producing documents for SEC review.
• Eligible to be fingerprinted and submitted for an FBI criminal history record check through an approved channeler under Rule 17f-2; this is a condition of appointment.
• Regulatory accountability and comfort with personal responsibility for the registrant’s standing.
• Independence in reaching SAR decisions and perimeter positions without first seeking operational comfort.
• Intellectual honesty, including communicating when a counsel position has not yet been reached.
• Capacity awareness and willingness to flag when the combined role becomes too much for one person.
• Attention to detail and a high standard of accuracy in processing, documentation, and control evidence.
• Adaptability in a growth-stage environment where processes or answers may not yet exist, and willingness to help build what is missing.
• Ability to explain operational and regulatory matters clearly to colleagues, auditors, counterparties, and regulators.

Nice To Haves

• Exposure to tokenised securities, digital assets, or DLT-based settlement, and to the transfer agent versus clearing agency boundary question.
• Familiarity with verifiable credentials or on-chain eligibility enforcement as a compliance control.
• Experience of a transfer agent registration from a standing start.
• Experience overseeing an offshore or intra-group operational provider from a US registrant.
• Legal qualification or prior regulatory experience.

Responsibilities

• Own SEC transfer agent registration and the Form TA-1 and TA-2 cycle, including amendments when officers, control persons, or activities change.
• Own and maintain the registrant’s written supervisory procedures, ensuring they reflect actual operations.
• Own SEC examination readiness, including records, walkthroughs, control evidence, and the narrative explaining the digital-native register.
• Own the annual study and evaluation of internal accounting control under Rule 17Ad-13, including the technology layer.
• Own and defend the written position on the custody and activity perimeter, including that ZILO holds no client money, fund units, tokens, or private keys.
• Act as designated AML officer for the fund programme, owning policy, risk assessment, procedures, training, and coordination of independent testing.
• Own suspicious activity report investigations, decisions, and filings with FinCEN.
• Oversee the customer identification programme, ongoing due diligence, and sanctions and PEP screening for US investors.
• Oversee transaction monitoring across fiat and digital asset legs, and own the wallet freeze and unfreeze position when financial-crime triggers arise.
• Own compliance with the 17Ad rule set concerning turnaround, recordkeeping, the control book, aged record differences, safeguarding, and instruction authentication.
• Own the Regulation S-P position, including investor information safeguarding, incident response, and breach notification.
• Own the conflicts of interest register, financial crime prevention procedures covering fraud, bribery, and tax evasion, and the whistleblowing channel.
• Map conditions attached to comparable no-action and exemptive relief in the product area and track whether the model remains within them.
• Provide second-line challenge to operational processing delivered by the UK hub for the US line, including a compliance monitoring programme with its own testing.
• Own compliance-side oversight of external service providers, including the boundary that places the distribution partner outside supplier oversight while keeping the custodian inside it.
• Report on compliance and financial crime matters to the COO, ZILO US board, and fund board.
• Own the compliance position for investor eligibility credentials, ensuring credential assertions and conditions reflect the rules, eligibility is withdrawn when investor status changes, and the position is documented and evidenced.
• Escalate when workload or independence requirements mean a task should sit elsewhere.

Benefits

• Competitive base salary; compensation details on application.
• Comprehensive US benefits package including medical cover, a 401(k) plan, paid time off, and US public holidays.
• Full benefits details available on application.

What This Job Offers

• Job Type: Full-time
• Career Level: Senior
• Education Level: No Education Listed