Chief Compliance Officer – BSA Officer

This is a fully remote position, open to applicants in Nebraska.

📋 Description

• Update, implement, and sustain a risk-based BSA/AML/CFT and OFAC program encompassing internal controls, independent testing, a designated BSA Officer, training, and customer due diligence, including beneficial ownership.

• Draft and annually refresh BSA/AML and sanctions policies, procedures, and the Board-approved risk appetite.

• Provide program status updates, metrics, and significant issues to the Board and senior management at least quarterly.

• Own the enterprise BSA/AML and sanctions risk assessment.

• Oversee CIP, KYC, KYB, and enhanced due diligence for retail, institutional, and VASP/counterparty customers.

• Establish customer risk-rating methodology and periodic review cycles.

• Approve the onboarding of high-risk customers.

• Supervise fiat and on-chain transaction monitoring and blockchain analytics.

• Adjust scenarios and thresholds; document model validation and testing.

• Address digital asset typologies such as mixers, darknet markets, ransomware, chain-hopping, bridge exploits, and sanctioned addresses.

• Implement compliance with FinCEN Recordkeeping and Travel Rule, along with FATF Recommendation 16.

• Conduct OFAC and global sanctions screening; manage blocking, rejection, and reporting obligations.

• Oversee alert and case investigations; make final decisions on SAR filings.

• Ensure accurate and timely execution of CTRs, 314(a) responses, 314(b) information sharing, subpoenas, and law enforcement responses.

• Establish AML controls for stablecoin issuance, redemption, reserves-related flows, and freeze/blacklist capabilities.

• Ensure that custody and wallet-management processes adhere to requirements.

• Act as the primary contact for regulatory examinations and independent audits; manage remediation efforts.

• Deliver role-specific BSA/AML training.

• Evaluate and supervise third-party compliance vendors and partner-bank or program-manager arrangements.

• Build, staff, and lead the financial crimes compliance team; establish QA standards and KPIs.

• Design a scalable compliance operating model and plan for staffing, tooling, and process requirements.

• Foster talent through career paths, succession planning, and professional development initiatives.

• Collaborate with Product and Engineering to integrate compliance controls into new products.

• Manage the compliance function’s P&L and annual budget.

• Develop compliance investment business cases and present them to senior management and the Board.

• Monitor compliance unit costs and identify efficiencies.

• Work with Finance and business leaders on compliance costs and risks related to pricing, market entry, and partnerships.

• Negotiate and oversee vendor contracts.

⛳️ Requirements

• Bachelor’s degree in finance, criminal justice, law, business, or a related field.

• 8+ years of BSA/AML compliance experience at a bank, trust company, or regulated money transmitter, including 3+ years as a BSA Officer, deputy, or program lead.

• 2+ years of direct experience with digital assets, virtual currency, or a VASP/crypto exchange.

• Practical experience leading regulatory examinations and addressing findings.

• Proven experience in SAR decision-making and investigation management.

• Working knowledge of the BSA, USA PATRIOT Act, AML Act of 2020, FinCEN CDD Rule, OFAC regulations, and FATF virtual asset guidance.

• A demonstrated history of building or scaling a compliance function amid significant growth, including managing a departmental budget.

• One or more certifications: CAMS, CAMS-FCI, CRCM, or CFE.

• Authorized to work in the United States.

• Advanced digital asset AML certification (e.g., CCAS, CCI, or Chainalysis/TRM investigator certification) preferred.

• Experience at a de novo bank, in a charter application, or with state trust or digital asset charters preferred.

• Familiarity with stablecoin programs, including issuer-side controls, preferred.

• JD, MBA, or another advanced degree preferred.

• Knowledge of smart contracts, wallet architecture, and on-chain data analysis (e.g., SQL against blockchain data) preferred.

🏝️ Benefits

• An executive leadership position at a pioneering digital asset bank.

• The chance to establish the Bank’s compliance function from the ground up and influence its risk culture.

• Direct access to the Board and senior leadership.

• Experience with cutting-edge blockchain and payment technologies.