Manager, Compliance/ MLO/ Risk - Bullish DE

Focused on developing products and services for the digital assets sector, Bullish has rewired the traditional exchange to benefit asset holders, enable traders and increase market integrity. Supported by the group’s treasury, Bullish’s new breed of exchange combines deep liquidity, automated market making and industry-leading security and compliance to increase the accessibility of digital assets for investors. Bullish exchange is operated by Bullish (GI) Limited and is regulated in Gibraltar.

Bullish through its German subsidiaries (Bullish DE) have applied for a crypto custody and principal brokerage/proprietary trading licenses. In line with these commitments we are expanding into Germany.

Mission: To make trading with digital assets more rewarding and secure.

Vision: To be the most innovative, respected, and trusted leader in crypto.

Reports to: Deputy General Counsel, Head of Regulatory Affairs

The Role

The role is principally responsible for establishing and managing the policies, systems, and processes to counter the risks of Bullish DE’s involvement in money laundering, terrorism financing, weapons proliferation and sanctions evasion, bribery, and corruption or other criminal activities, as well as for filing Suspicious Transactions Reports (STRs) to the competent authority.

Key Responsibilities

1. Working with the Managing Director, Back Office/ Bullish DE Head of Compliance to ensure the implementation of effective policies, procedures and controls to comply with the legal rules and regulations that are material to Bullish DE.
2. Support and advise the Bullish DE Management Board with regard to complying with applicable German/ EU legal rules and regulations.
3. Regularly identify and advise the Bullish DE Management Board the material legal rules and regulations, non-compliance with which might jeopardise the institution's assets, in the light of risk factors.
4. Develop, implement and manage Bullish DE’s general compliance programme under MICA, MiFID II and EMIR in order to ensure that Bullish DE can meet its legal and regulatory obligations, including ensuring that appropriate policies, processes and controls are in place to meet such requirements, including:
1. Financial crime compliance;
2. Market conduct compliance;
3. Compliance with client and business conduct requirements, such as product suitability and best execution obligations;
4. Obligations with respect to client assets and moneys held in custody.
5. Develop, implement and manage the Bullish DE’s financial crime compliance programme and support and assist Bullish DE in meeting its financial crime compliance obligations, including:
1. Assess and monitor financial crime risk and the exchange’s compliance with its financial crime obligations;
2. Escalate issues to Managing Director and/or the Management Board;
3. Where necessary, update the relevant stakeholders and committees on the financial crime risk profile of Bullish DE;
4. Conduct employee financial crime compliance training and awareness;
5. Assist management in developing and maintaining an effective financial crime compliance culture;
6. In consultation with management, create and maintain the financial crime risk-based approach and the risk assessment of the exchange’s customers, products and services;
7. Draft and maintain up to date financial crime compliance policies and procedures;
8. Oversee the operation of Bullish DE’s ongoing customer due diligence programme;
9. Ensure that appropriate financial crime compliance controls are in place;
10. Ensure all internal suspicious activity alerts received are investigated without delay;
11. Ensure that a Suspicious Activity Report is submitted to the relevant law enforcement agency in Germany in compliance with Bullish DE’s legal obligations;
12. Remain aware of any relevant sanctions, prohibition or advisory notices. Also, if necessary, advise management and relevant staff of the names of any individuals and institutions on the sanctions list;
13. Implement improvements to the financial crime compliance programme.
6. Develop, implement and manage Bullish DE’s market integrity surveillance programme in accordance with MICA and relevant RTSs to be issued by ESMA, including:
1. Draft and maintain up to date market integrity policies and operating procedures;
2. Ensuring adequate market surveillance controls are implemented;
3. Ensuring any alerts generated by the market surveillance systems are promptly investigated and a course of action determined;
4. Ensuring that Bullish DE complies with any market conduct related regulatory reporting obligations.
7. Oversight over Bullish DE’s pre-trade and post trade reporting program to ensure compliance with its reporting obligations in accordance with all applicable regulations, including EMIR post trade transparency reporting obligations.
8. Develop, implement and manage Bullish DE’s enterprise risk framework and business continuity plan according to all applicable regulatory requirements and in particular MaRisk, including:
1. Ensure that Bullish DE’s risks are regularly assessed and its risk appetites are kept up to date;
2. Maintain Bullish DE’s risk strategy and ensure the ongoing effectiveness of the risk management process;
3. Manage the third-party risk management programme including required risk assessments;
4. Ensure that Bullish DE’s business continuity program is implemented and effective.
9. Assist Bullish DE’s management in promptly responding to any reasonable request for information from the regulator and/or law enforcement agencies.
10. Provide guidance to the first line of defence in relation to all German/ EU compliance matters, including the German Banking Act, MiFID II/ EMIR and MiCA.
11. Keep the business abreast of relevant regulatory changes in Germany and the EU applicable to Bullish DE and provide advice on the impact of and compliance with such changes. Where applicable, update the policies, procedures, and training manuals to reflect all regulatory changes.
12. Recommend any changes to the policies, operating procedures and training, as required, resulting from such regulatory changes.
13. Assist in the investigation of any suspected breaches of legal or regulatory requirements or internal compliance policies and standards and prepares reports on such breaches.
14. Develop and manage Bullish DE’s enterprise risk and business continuity programme according German and EU regulatory requirements, including:
1. Ensuring that the local enterprise risk management framework is regularly reviewed and up to date;
2. Maintaining and updating Bullish DE’s risk taxonomies and risk registers regularly.

Experience & Qualifications

1. Familiarity with German/ EU laws and regulations applicable to crypto services providers and MiFID II investment firms trading in derivatives, including the German Banking Act, MiFID II, EMIR and the related guidances issued by BaFIN.
2. German fully qualified lawyer/CPA with an acknowledged professional compliance certification, particularly in AML/CFT.
3. Sufficient experience compliance position at a banking, cryptocurrency, trading, exchange, blockchain or payments institution.
4. Sufficient knowledge of the German AML Act (Geldwäschegesetz – GwG).
5. Experience in developing, implementing and periodic monitoring of compliance policies, AML/CFT requirements.
6. Solid knowledge of relevant IT processes, which is used to conduct suspicious transactions and/or activities by e-trading and cryptocurrency transactions.
7. Familiarity with frameworks such as COBIT, NIST or certifications in BCM, CIA, CISA, CRISC a plus.
8. Resident in Germany.
9. Fluent in English. German language skills are preferred but not essential.

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.