Compliance Officer and MLRO - US (Digital Transfer Agency)

ZILO • Boston, MA

3d

About The Position

This role owns compliance for ZILO’s registered transfer agent in the United States, including the Section 17A and 17Ad rule set and the registrant’s 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 holder sets and documents the compliance standard for the US line and serves as the primary regulatory contact on how that standard is met.

The position carries both the regulatory compliance and financial crime mandate for the US entity. It requires clear escalation when workload or independence requirements mean an activity should be handled elsewhere. The role also owns the compliance position behind investor eligibility credentials issued and maintained by ZILO, including the assertions each credential makes, alignment with applicable rules, withdrawal when investor status changes, and documentation that can be explained to regulators and evidenced in practice.

The role provides second-line oversight of operational processing delivered by the UK hub for the US line, including independent compliance monitoring and testing. It reports to the COO, the ZILO US board, and the fund board on compliance and financial crime matters.

Requirements

• Senior compliance experience in a US SEC-registered transfer agent, fund administrator, or comparable registrant, with direct ownership of the 17Ad rule set.
• Direct experience preparing a registrant for an SEC examination and responding to findings.
• Prior designated AML officer experience 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; the role produces documents the SEC will read.
• 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 regulatory perimeter positions without first seeking operational comfort.
• Intellectual honesty, including identifying when a counsel position has not yet been reached.
• Capacity awareness and willingness to flag when the combined role exceeds what one person can handle.
• Attention to detail and 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.
• Clear communication with colleagues, auditors, counterparties, and regulators.

Nice To Haves

• Exposure to tokenised securities, digital assets, or DLT-based settlement, including the transfer agent versus clearing agency boundary question.
• Familiarity with verifiable credentials or on-chain eligibility enforcement as a compliance control.
• Experience establishing 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 explanations of the digital-native register.
• Own the annual Rule 17Ad-13 study and evaluation of internal accounting control, including the technology layer.
• Own and document the custody and activity perimeter position 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 investigation, decision-making, and filing with FinCEN.
• Oversee the customer identification programme, ongoing due diligence, and sanctions and politically exposed person screening for US investors.
• Oversee transaction monitoring across fiat and digital asset legs, and own wallet freeze and unfreeze positions when financial crime triggers arise.
• Own compliance with the 17Ad rule set as it applies to turnaround, recordkeeping, the control book, aged record differences, safeguarding, and instruction authentication.
• Own the Regulation S-P position, including investor information safeguards, 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 independent testing.
• Oversee external service providers from the compliance side, including maintaining the boundary that excludes the distribution partner from supplier oversight while including the custodian.
• Report compliance and financial crime matters to the COO, ZILO US board, and fund board.
• Own the compliance position on investor eligibility credentials, including their assertions, regulatory basis, withdrawal when investor status changes, and supporting documentation.

Benefits

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

What This Job Offers

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