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:

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:

BSA/AML & Sanctions Oversight

• 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, escalate, 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 controls that address emerging risks and evolving industry practices and regulatory requirements.
• Develop and maintain compliance controls for tokenized securities, including wallet whitelisting, investor eligibility verification, transfer restrictions, and on-chain transaction monitoring.
• Assess proposed token listings, blockchain networks, smart contract upgrades, and bridge mechanisms for financial crime, sanctions, and other compliance risks.
• Translate on-chain transaction activity and smart contract data into actionable findings to support suspicious activity investigations, regulatory reporting, and law enforcement requests.

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 US laws, international and industry standards.
• Demonstrated proficiency using enterprise blockchain forensics platforms (e.g., Chainalysis Reactor/KYT, TRM Labs, Elliptic Forensics) to trace complex transaction paths and produce investigative summaries.
• Working knowledge of smart contract mechanics, token standards (e.g., ERC-20, ERC-1400, ERC-3643), permissioned wallet registries, and the ability to assess the impact of U.S. and international securities laws on on-chain trade execution, settlement, custody, and regulatory reporting.
• 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.
• 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.

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.