BSA/AML Officer & Blockchain Compliance

Bullish US; New York (NY); On-site; USD 120,000 - 190,000; Full time

Job summary

Bullish is seeking a BSA/AML Officer for our NYC-based US regulated entities to lead compliance for spot, derivatives, and tokenized securities. You will manage BSA/AML and OFAC programs, oversee regulatory reporting, and work with Legal, Product, and Engineering to implement on-chain trading controls.

The role reports to the US Chief Compliance Officer and requires deep blockchain compliance expertise. Based in NYC, you will drive risk-based controls and strengthen the compliance culture across

Responsibilities

• Lead the compliance program for tokenized securities, derivatives, and spot crypto trading to meet regulatory 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 addressing all areas and advise on deficiencies and changes.
• Direct the domestic BSA/AML and OFAC monitoring program to ensure strong internal controls.
• Coordinate with offshore affiliates to ensure controls meet U.S. standards.
• Oversee regulatory reporting to FinCEN, SEC, CFTC, FINRA, NFA, NYDFS and others, including SAR filings.
• Prepare monthly and quarterly management reporting of BSA/AML-related metrics.
• Identify, elevate, track and remediate BSA/AML compliance issues.
• Perform BSA/AML, CIP, and OFAC risk assessments and use data to improve programs.
• Lead the process for filing all required reports and maintaining records per regulations.
• Contribute to a culture of compliance by training employees on policies and responsibilities.

Job description

About Bullish

Bullish is an institutionally focused global digital asset platform that provides market infrastructure and information services. These include: Bullish Exchange - a regulated and institutionally focused digital assets spot and derivatives exchange, integrating a high-performance central limit order book matching engine with automated market making to provide deep and predictable liquidity. Bullish Exchange is regulated in Germany, Hong Kong, and Gibraltar. CoinDesk Indices - a collection of tradable proprietary and single-asset benchmarks and indices that track the performance of digital assets for global institutions in the digital assets and traditional finance industries. CoinDesk Data - a broad suite of digital assets market data and analytics, providing real-time insights into prices, trends, and market dynamics. CoinDesk Insights - a digital asset media and events provider and operator of Coindesk.com , a digital media platform that covers news and insights about digital assets, the underlying markets, policy, and blockchain technology.

Reports To

Chief Compliance Officer, US Regulated Entities

Position Overview

We are seeking a BSA/AML Officer with deep Blockchain Compliance expertise to play a key role in the business expansion of our regulated US digital currency trading business. In this role, you will support the spot, derivative, and tokenized securities business lines in the US, encompassing the MTL businesses (spot), FCM, and Broker Dealer entities. As the BSA/AML Officer, 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. You will also bring specialized knowledge of blockchain structures, networks, and on-chain activities to help our U.S. businesses develop and implement appropriate processes and controls supporting spot trading, derivatives, and tokenized securities activities.

This position is based in NYC and will be required to work from our NYC office. The role reports to the US Chief Compliance Officer.

Responsibilities:

• Lead the compliance program for tokenized securities, derivatives, and spot 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; Sanctions compliance; fraud risk; market integrity; Compliance with state licensing 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").
• 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.

Blockchain Intelligence & Tokenization Compliance

• Act as the lead compliance investigator and subject-matter specialist for blockchain analytics, wallet clustering, and transaction tracing across spot trading, derivatives margin/settlement, and tokenized assets.
• Conduct hands-on forensic investigations into flagged deposit and withdrawal addresses using enterprise blockchain tools (e.g., Chainalysis, TRM Labs, Elliptic), tracing funds through bridges, decentralized protocols, and mixing services.
• Play a key role in building Bullish's U.S. tokenized securities business, working with Legal, Product, and Engineering to develop processes and controls for on-chain trading, custody, settlement, and transfer activities.
• Apply expertise in blockchain networks, smart contracts, and tokenization structures to design and implement con