BSA/AML Officer

Bullish; New York (NY); On-site; USD 175,000 - 215,000; Full time

Job summary

Bullish US LLC is seeking a senior BSA/AML Officer to lead the US compliance program for the regulated digital currency trading business in New York City. The role requires driving BSA/AML and OFAC controls, coordinating with regulators, and maintaining compliance across spot, derivatives, and tokenized securities.

Responsibilities include advisory on deficiencies, regulatory examinations, risk assessments, and training to build a strong compliance culture.

Qualifications

• Experience in financial crime, BSA/AML, and risk management with exposure to digital assets.
• Experience managing regulatory examinations with entities such as NYDFS, FINRA, NFA, SEC, CFTC.
• Extensive knowledge of BSA, USA PATRIOT Act, OFAC, and related rules and requirements.
• Attention to detail with strong organizational, analytical, and problem-solving skills.
• Ability to operate in a fast-paced, high-demand environment with multiple priorities.
• Bachelore2 s Degree required; advanced degree preferred; licenses desirable.

Responsibilities

• Lead the compliance program for fiat and crypto trading to meet regulatory requirements and manage risk.
• Implement and oversee domestic BSA/AML and OFAC compliance programs in line with US regulations.
• Maintain risk-based BSA/AML and OFAC policies; advise staff and management on deficiencies.
• Direct the BSA/AML and OFAC monitoring program to ensure effective controls.
• Coordinate with offshore affiliates to ensure US-standard controls are met.
• Oversee regulatory reporting to FinCEN, SEC, CFTC, FINRA, NFA, NYDFS and others; file SARs timely.
• Ensure adherence to FINRA Rule 3310 and NFA Rule 2-9(c) where applicable.
• Prepare monthly/quarterly BSA/AML metrics for management reporting.
• Identify, escalate, and remediate BSA/AML compliance issues.
• Lead risk assessments and use data to inform program improvements.
• Ensure timely filing of all BSA/AML and OFAC reports and maintain related records.
• Contribute to a culture of compliance through training and awareness.
• Refine alert thresholds and monitoring configurations to detect suspicious activity.
• Represent Bullish in regulator meetings and audits; coordinate examinations.

Skills

Financial crime

BSA/AML

AML program management

Regulatory compliance

Audits/regulatory examinations

Risk management

CIP/OFAC

Cross-functional leadership

Education

Bachelore2 s Degree / University degree

Advanced degree (JD, MBA, etc.) preferred

Job description

Position Overview

We are seeking a BSA/AML Officer for Bullish’s regulated US digital currency trading business. In this role, you will be a key pillar in our US business expansion by leading the US Compliance program and acting as the regional BSA/AML Officer. This role supports the spot, derivative, and tokenized securities business lines in the US, encompassing the MTL businesses (spot), FCM, and Broker Dealer entities. In this role, you will be responsible for our BSA/AML & OFAC Sanctions programs and ensuring that we maintain compliance with all applicable local, US, and international laws and regulations impacting the digital currency industry.

This position is based in NYC and will be required to work from our NYC office a minimum of 4 days per week.

Responsibilities

• Lead the compliance program for both fiat and crypto trading to meet all applicable state and federal regulatory requirements and reflect the nature of a rapidly changing risk landscape, including:
  • BSA/AML compliance;
  • fraud risk;
  • market integrity;
  • Compliance with state licensing requirements;
  • Oversight over compliance with applicable state and federal cybersecurity requirements;
  • Other business conduct requirements.
• Implement the domestic BSA/AML and OFAC compliance programs in line with U.S. regulatory requirements.
• Maintain risk‑based BSA/AML and OFAC policies and procedures addressing all areas of BSA/AML and OFAC; advise Bullish staff and management of deficiencies and ensure that required changes are made.
• Direct the domestic BSA/AML and OFAC compliance monitoring program to ensure there are sufficient internal controls to promote an effective control environment.
• Coordinate with offshore affiliates and exercise oversight to ensure any controls performed on behalf of the U.S. entity by the affiliates are performed to a standard that meets U.S. requirements.
• Oversee regulatory reporting to FinCEN, SEC, CFTC, FINRA, NFA, NYDFS, and other federal and state regulators, as necessary, to comply with Bullish’s BSA/AML reporting obligations, including ensuring the timely filing of suspicious activity reports (“SARs”).
• Ensure the BSA/AML program strictly adheres to FINRA Rule 3310 (for the Broker Dealer) and NFA Compliance Rule 2‑9(c) (for the FCM).
• Prepare monthly and quarterly management reporting of BSA/AML‑related metrics.
• Identify, elevate, track, and remediate, as necessary, BSA/AML compliance‑related issues.
• Perform BSA/AML, CIP, and OFAC risk assessments as needed and work with stakeholders and various forms of data to inform, update, streamline and optimize the BSA/AML and OFAC program.
• Lead the process for ensuring all BSA/AML and OFAC reports are filed as required and all BSA/AML and OFAC related records are maintained according to regulatory requirements.
• Contribute to building a compliance culture across the firm by training Bullish employees on key policies, procedures, and their responsibilities in preventing financial crime.
• Continually review and refine alert thresholds and organizational configurations in the transactional monitoring system to ensure alerts are appropriately set and suspicious activity is detected as expected.
• Coordinate with and serve as point‑of‑contact for audits and regulatory examinations of the compliance program and represent Bullish in meetings with regulators.

Experience & Qualifications

• Sufficient experience in one or a combination of the following to satisfy the requirements to be appointed into the role: financial crime, Bank Secrecy Act (BSA), Anti‑Money Laundering (AML), financial crime investigations, and/or risk management, audit, compliance, specifically with exposure to digital assets.
• Experience in managing regulatory examinations and relationships with examiners (e.g., NYDFS, FINRA, NFA, SEC, CFTC), auditors, and banking partners.
• Extensive knowledge of the Bank Secrecy Act (BSA), USA PATRIOT Act, OFAC regulations, as well as SEC, CFTC, FINRA, and NFA rules and requirements.
• Awareness of regulatory requirements including local and U.S. laws, international and industry standards.
• Strong attention to detail and strong organizational, problem‑solving, analytical, and management skills.
• Ability to execute in a fast‑paced, high‑demand environment while managing multiple priorities.
• Bachelor’s Degree/University degree or equivalent experience; Advanced degree (e.g., JD, MBA, etc.) preferred.
• Active FINRA Series 7 and 24 (or 14) licenses, and Series 3 are strongly preferred (or willingness to obtain them within a specified timeframe).
• Certified Anti‑Money Laundering Specialist (CAMS), Certified Fraud Examiner (CFE), Certified Regulatory Compliance Manager (CRCM), Certified Financial Crime Specialist (CFCS) and/or related professional certification preferred.

Bullish US LLC & CoinDesk Inc. are committed to offering competitive compensation and benefits. The anticipated base salary for this position is $175,000 - $215,000 + discretionary annual target bonus + performance incentives/benefits. Offered salary will be reflective of job‑related knowledge, skills and commensurate experience.

Equal Opportunity Employer

Bullish is proud to be an equal opportunity employer. We are fast evolving and striving towards being a globally‑diverse community. With integrity at our core, our success is driven by a talented team of individuals and the different perspectives they are encouraged to bring to work every day.