The Head of Compliance will lead the development, implementation and oversight of HODLife’s Group-wide compliance framework, covering regulatory compliance, business conduct and financial crime compliance across the jurisdictions in which the Group operates.
This is a hands-on leadership role supporting the growth of a life insurance business operating at the intersection of insurance and digital assets. The role will translate regulatory requirements into practical controls, provide independent challenge and help the business develop products, distribution channels and partnerships within applicable regulatory requirements and approved risk appetite.
The role will work closely with Legal, Risk, Operations, Product, Finance and the CISO, while maintaining clear accountability for the compliance function and independent escalation of material concerns.
Key Responsibilities
1. Compliance Strategy, Governance & Oversight
- Own the Group compliance framework, policies and annual risk-based compliance plan, proportionate to the business’s scale, complexity and growth.
- Maintain an inventory of applicable regulatory obligations, licence conditions and commitments, with clear business owners, controls and reporting deadlines.
- Report material compliance risks, breaches, emerging issues and remediation progress to senior management and the Board or relevant committee; elevate unresolved concerns independently.
- Establish clear responsibilities between Group Compliance, local compliance officers, business teams and external advisers; identify resource and capability needs.
2. Regulatory Compliance & Engagement
- Oversee the Local, Bermuda head of Compliance, and any other compliance staff hired throughout the Group. Also continuously monitor that sufficient Compliance resources are available to protect the Group, and communicate with the business head(s), Finance and other functions if additional resources are needed.
- Lead compliance engagement with the Bermuda Monetary Authority and other relevant regulators, coordinating with Legal and locally appointed officers as appropriate.
- Monitor regulatory developments and translate them into policy, process and control changes; oversee implementation and evidence of compliance.
- Coordinate regulatory inspections, enquiries, compliance submissions and breach notifications, and track regulatory commitments through to completion.
- Partner with Legal on licensing, market entry, cross-border activities and material changes to products, distribution arrangements and business plans, identifying required approvals or notifications before implementation.
3. Financial Crime Compliance & MLRO Responsibilities
- Own the AML/CTF, sanctions, anti-bribery and corruption, and fraud compliance frameworks, including enterprise-wide financial crime risk assessments.
- Oversee customer and beneficial-owner due diligence, enhanced due diligence, source-of-wealth and source-of-funds assessments, screening, transaction monitoring and ongoing reviews.
- Provide decisions and escalation on high-risk relationships and complex transactions within delegated authority; oversee suspicious activity investigations and related remediation.
- Serve as MLRO or equivalent where formally appointed and eligible, subject to applicable local requirements and regulatory approval where required; oversee confidential reporting to the relevant authorities and coordinate with local MLROs.
- Develop compliance standards for digital asset-related products, transactions and partnerships relevant to HODLife’s business model, including stablecoins and tokenised assets where applicable.
- Assess digital asset provenance, wallet ownership or control, on-chain exposure and risks associated with self-hosted wallets, exchanges, custodians and other service providers.
- Oversee the use of blockchain analytics, wallet screening and transaction-monitoring tools, including alert escalation, investigation standards and control effectiveness.
- Work with Legal to assess applicable digital asset licensing and transfer-information requirements, including the Travel Rule where applicable, and conduct compliance due diligence on digital asset partners.
5. Product, Distribution & Business Conduct
- Provide compliance review and challenge for new products, customer journeys, marketing materials, digital onboarding and distribution partnerships before launch.
- Oversee conduct standards covering fair treatment of policyholders, disclosures, suitability where applicable, conflicts of interest, sales practices and complaints handling.
- Assess intermediary and referral arrangements, remuneration structures and cross-border solicitation risks; monitor compliance with agreed distribution controls.
- Give clear, timely and commercially practical advice, identifying compliant options and escalating proposals that fall outside regulatory requirements or approved risk appetite.
6. Monitoring, Remediation & Compliance Culture
- Design and execute risk-based compliance monitoring and testing; document findings, agree corrective actions with accountable owners and verify closure.
- Maintain compliance incident and breach registers; coordinate investigations and root‑cause reviews with Legal, Risk, HR and the CISO as appropriate.
- Deliver targeted training and maintain confidential channels for raising compliance concerns.
- Partner with the CISO and Data Protection Officer on technology, outsourcing, data protection and incident-related regulatory obligations. Cybersecurity operations remain with the CISO; business teams retain ownership of operational controls.
Requirements
Experience & Qualifications
- Typically 12+ years of relevant compliance experience in regulated financial services, including senior responsibility for a broad compliance programme and financial crime oversight.
- Demonstrable hands‑on digital asset compliance experience is essential, gained in a regulated digital asset business or through substantive responsibility for digital asset activities within a financial institution.
- Strong understanding of life insurance products, distribution and policyholder protection; direct life insurance compliance experience is strongly preferred.
- Proven experience engaging regulators, advising senior management and Boards, and managing regulatory reviews, monitoring programmes and remediation.
- Familiarity with Bermuda insurance regulation is advantageous; experience across Hong Kong and/or UAE regulatory environments is desirable, depending on the Group’s activities.
- Ability to build and operate practical compliance frameworks in a lean, growing organisation, combining strategic judgement with direct execution.
- Sound judgement, integrity and the confidence to challenge senior stakeholders constructively; ability to explain complex requirements clearly.
- Degree in law, finance, business or a related discipline, or equivalent professional experience. Relevant compliance or financial crime qualifications, such as ICA or CAMS, are desirable.