Chief Compliance / BSA Officer - (Custody / Digital Assets / Fintech)
Chief Compliance / BSA Officer Location: United States Reports To: CEO (administratively), Board of Directors / Audit Committee (functionally) Employment Type: Full-time About Ceffu Ceffu is a leading global digital asset custody provider, serving institutional clients with secure, compliant custody solutions for cryptocurrencies and digital assets. We are establishing a US Regulated Entity to expand our regulated custody services in the United States market. Position Overview This combined role is responsible for both the company's comprehensive compliance program AND the Bank Secrecy Act / Anti-Money Laundering program. The CCO/BSA Officer ensures adherence to all applicable federal, state, and local laws and regulations, with particular accountability for BSA/AML compliance including SAR filing authority. This is a senior, dual-mandate position requiring expertise in both general compliance and financial crimes prevention. You will serve as a key regulatory contact and must be directly employed by the company. The role works closely with Ceffu's global operations team for monitoring support but retains ultimate US-based accountability for all compliance and BSA matters. Key Responsibilities 1) Compliance Program Management
- Design, implement, and maintain a comprehensive compliance management system
- Develop and update compliance policies, procedures, and controls
- Conduct regular compliance risk assessments
- Monitor regulatory changes and assess impact on operations
- Ensure compliance training for all staff (US and global team members)
- Serve as primary compliance contact for State Bank Commissioner
- Coordinate regulatory examination preparation and response
- Prepare and submit required regulatory reports and filings
2) BSA/AML Program Management
- Develop, implement, and maintain the BSA/AML compliance program
- Ensure program meets requirements of BSA, USA PATRIOT Act, and FinCEN regulations
- Conduct annual BSA/AML risk assessment
- Serve as the designated BSA Officer with authority to implement the program
- Update policies and procedures based on regulatory changes and risk assessment findings
- Coordinate with global AML operations team for monitoring support
3) Transaction Monitoring & Investigations
- Oversee transaction monitoring program (leveraging global team for operations)
- Review escalated alerts and investigate suspicious activity
- Make final determination on SAR filing decisions
- Ensure quality control of monitoring processes
- Document investigation findings and decisions
4) Regulatory Filings & Reporting
- File Suspicious Activity Reports (SARs) with FinCEN
- Ensure accurate and timely Currency Transaction Reports (CTRs)
- Submit required FinCEN reports and filings
- Maintain records of all filings per regulatory requirements
- Respond to law enforcement requests (314(a), subpoenas, etc.)
- Prepare and submit required regulatory reports to State Bank Commissioner
5) OFAC & Sanctions Compliance
- Administer OFAC sanctions screening program
- Review and resolve sanctions alerts
- Ensure screening of customers, transactions, and counterparties
- Monitor changes to sanctions lists and update procedures
6) Customer Due Diligence
- Oversee Customer Identification Program (CIP)
- Ensure appropriate customer due diligence (CDD) and enhanced due diligence (EDD)
- Review and approve high-risk customer relationships
- Monitor customer risk ratings and update as needed
7) Crypto-Specific Compliance & AML
- Monitor evolving regulatory guidance on digital assets
- Implement blockchain analytics and crypto transaction monitoring
- Stay current on FinCEN guidance for virtual asset service providers
- Develop typologies for crypto-specific money laundering risks
- Ensure compliance with state and federal crypto custody requirements
- Coordinate with global team on crypto-specific compliance matters
8) Advisory & Training
- Advise CEO and Board on compliance and BSA/AML matters
- Review new products, services, and initiatives for regulatory implications
- Assess compliance aspects of third-party/affiliate relationships
- Develop and deliver compliance and BSA/AML training programs
- Maintain training records and certifications
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