Chief Compliance Officer / BSA Officer
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Remote | United States | Full-time Employment | Crypto MSB
About the company
Our client is an established, profitable fintech operating at the intersection of crypto and traditional payments. It runs a consumer on/off-ramp platform and a fast-growing B2B infrastructure business: APIs and white-label solutions that let exchanges, neobanks, PSPs, wallets and other platforms embed regulated crypto and fiat services. The group is authorised under MiCA and PSD2 in the EU, is registered in Canada, and is expanding its licence footprint in Europe and the UK. Its US entity is registered with FinCEN as a Money Services Business. The culture is owner-led, high-ownership and low-bureaucracy: decisions are made quickly and close to the founders.
About the role
This is a senior, hands-on role and a statutory one. You will be the designated BSA Officer and Chief Compliance Officer of the company’s US Money Services Business. You will report to the Board and work closely with the Global Chief Compliance Officer on framework and policy.
The BSA/AML and OFAC programme is already in place: policies, risk assessment, SAR process, sanctions screening, training records and an independent review. Your mission is to keep it examination-ready on any given day and to raise it to the standard that supports US growth with banking partners, card acquirers and new integrations. You will make filing, exit and escalation decisions independently. Your decisions are not subject to commercial approval, and you will be expected to act as a fast, credible partner to Product and Operations rather than a bottleneck.
What you will own
- BSA/AML and OFAC programme: policies, procedures, enterprise-wide risk assessment, training and alignment with the group compliance framework, including where US law requires a stricter control.
- Monitoring and investigations: fiat and on-chain transaction monitoring, alert disposition, investigation standards and case documentation.
- SAR decisions: drafting, approving and filing SARs within the 30-day timeline, continuing-activity reviews, and SAR confidentiality.
- Sanctions: OFAC screening across customers, counterparties, wallet addresses and geolocation; match adjudication; blocked and rejected transaction reporting; crypto-specific sanctions typologies.
- Information requests: 314(a) responses, subpoenas and law-enforcement requests, and 314(b) information sharing.
- Customer and partner risk: KYC/EDD standards, customer risk rating, approval of high-risk and PEP relationships, and exit decisions.
- Vendor oversight: due diligence, configuration and performance of KYC, screening and blockchain-analytics vendors.
- Product review: BSA/OFAC assessment of new products, payment methods and partner integrations before launch.
- Examinations and assurance: IRS BSA examinations, FinCEN inquiries, sponsor-bank audits and the independent review, with evidence-based remediation of findings.
- Registration and governance: FinCEN MSB registration and Board reporting on programme status, filings, findings and emerging risk.
What we are looking for
- 7+ years of BSA/AML compliance experience in a US-regulated financial institution: MSB, money transmitter, bank, broker-dealer or regulated fintech.
- At least 3 years as a designated BSA Officer, Deputy BSA Officer or equivalent with filing authority. A CCO title is not required, but ownership at that level is.
- Hands-on programme ownership at a crypto exchange, VASP, crypto-native MSB or payments/fintech MSB. This means execution, not advisory work only.
- Deep working knowledge of the BSA/FinCEN MSB regime: 31 CFR Parts 1010 and 1022, SAR and CTR filing, the Funds Transfer and Travel Rules, MSB registration, and FIN-2019-G001.
- Direct experience drafting and filing SARs.
- OFAC sanctions experience, including crypto-specific exposure: SDN-listed wallet addresses, mixers and sanctioned exchanges.
- Experie...
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