Compliance Senior Manager & MLRO, Hong Kong

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:

Director, Compliance & MLO

Company Overview:

We are a leading digital asset exchange licensed and regulated by the Hong Kong Securities and Futures Commission (SFC). Our mission is to provide a secure, transparent, and compliant platform for institutional and retail investors to trade a diverse range of cryptocurrencies. We are committed to upholding the highest standards of regulatory compliance, security, and corporate governance.

Position Summary:

The MLRO & Compliance Senior Manager will be a key leader within the organization, responsible for overseeing and enhancing all aspects of our compliance framework and ensuring strict adherence to all relevant laws, regulations, and SFC licensing requirements. This individual will serve as the MLRO & Manager in Charge Compliance, be the primary point of contact with the SFC and other regulatory bodies and will be instrumental in continuing to build a robust culture of compliance throughout the company.

Key Responsibilities:

• Anti-Money Laundering (AML) / Counter-Terrorist Financing (CTF): Serve as the Money Laundering Reporting Officer (MLRO). Oversee the development and execution of the company's AML/CTF policies and procedures, including Know-Your-Customer (KYC) and transaction monitoring programs. Conduct regular risk assessments and manage suspicious activity reporting.
• Regulatory Compliance: Continue to develop, implement, and maintain a comprehensive compliance program that aligns with the SFC's regulatory framework for virtual asset trading platforms (VATPs), including the latest guidelines and circulars. This includes rules related to AML/CTF, client asset segregation, cybersecurity, and corporate governance.
• Regulatory Liaison: Act as the primary liaison with the SFC and other relevant regulatory and law enforcement agencies. Manage all regulatory reporting, inquiries, and examinations.
• Policy & Procedure Development: Draft, review, and update internal compliance policies, procedures, and controls to reflect changes in regulatory requirements and business operations.
• Compliance Monitoring & Testing: Design and implement a robust compliance monitoring program to ensure policies are being followed. Plan and execute internal compliance audits and assist with external regulatory audits.
• Risk Management: Work closely with the risk management team to identify, assess, and mitigate compliance risks across all business functions.
• New Product & Business Initiatives: Provide compliance guidance and approval for all new products, services, and business initiatives to ensure they meet regulatory standards before launch.
• Technology & Systems: Collaborate with the technology and security teams to ensure that our platform and systems are compliant with all relevant data protection, cybersecurity, and operational requirements.

Qualifications:

• Bachelor's degree in Law, Finance, Business Administration, or a related field. Professional compliance certifications (e.g., ACAMS, CFE, CPA) are highly desirable.
• A minimum of 5-8 years of experience in a senior compliance role within the financial services industry in Hong Kong.
• Should have direct, hands-on experience with SFC-regulated entities. Experience with cryptocurrency or other virtual asset businesses is a significant advantage.
• Proven expertise in designing and implementing robust AML/CTF programs, including KYC and transaction monitoring.
• Exceptional communication and interpersonal skills, with the ability to articulate complex regulatory concepts to diverse stakeholders, including senior management, employees, and regulators.
• Strong analytical and problem-solving skills with a meticulous attention to detail.
• Ability to work effectively in a fast-paced, dynamic environment.
• Excellent written and spoken English. Proficiency in Cantonese and/or Mandarin is a plus.

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.