Outsourcing Manager - 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: Chief Operating Officer

The Role

The role involves oversight and management of Bullish DE Custody GmbH (“Bullish DE”)’s outsourcing arrangements to comply with BaFin's regulatory requirements, including MaRisk, BaIT and MiCA. The role includes implementing and further developing effective outsourcing management, along with the necessary control and monitoring processes. It also supports the company in meeting its outsourcing requirements and coordinates and reviews outsourcing risk management. Through these tasks, all outsourcing activities are well-documented, compliant, and aligned with the company's strategic objectives, while also managing associated risks effectively.

Key Responsibilities

Risk Assessment and Management:

1. Conduct risk assessments before entering into outsourcing arrangements.
2. Identify, evaluate, and mitigate potential risks associated with outsourcing, including operational, financial, and reputational risks.

Due Diligence:

1. Perform due diligence on potential service providers to ensure they have the capability, capacity, and reliability to deliver the outsourced services.
2. Assess the service provider's financial stability, expertise, and compliance with relevant regulations.

Contract Management:

1. Develop and negotiate comprehensive outsourcing contracts that clearly define the scope of services, performance standards, and responsibilities of both parties including data protection, confidentiality, audit rights, and termination conditions.

Monitoring and Oversight:

1. Establish and maintain effective monitoring and oversight mechanisms to ensure that the service provider meets agreed-upon performance standards and complies with regulatory requirements.
2. Conduct regular reviews and audits of the service provider's performance and risk management practices.

Regulatory Compliance:

1. Ensure that outsourcing arrangements comply with BaFin's regulatory requirements and guidelines.
2. Maintain documentation and records of all outsourcing arrangements for regulatory review and reporting.

Business Continuity, Contingency & Exit Planning:

1. Develop and implement business continuity plans to address potential disruptions in outsourced services.
2. Ensure that contingency plans are in place to manage the failure of a service provider or the termination of an outsourcing arrangement.
3. Develop and implement exit plans for material outsourced service providers to ensure Bullish DE’s business is not impacted due to the need to exit such service providers.

Communication, Audit and Reporting:

1. Facilitate clear and effective communication between Bullish DE and the service providers.
2. Work with Bullish DE’s internal and external auditors to ensure the company’s outsourcing arrangements are implemented according to applicable regulatory requirements and standards.
3. Report significant outsourcing arrangements and any material changes to BaFin as required.

Internal Coordination:

1. Work closely with internal stakeholders, including legal, compliance, risk management, Operations, Security and IT departments, to ensure a coordinated approach to outsourcing.

Experience & Qualifications

1. Experience managing business outsourcing activities in accordance with BaFin requirements including assessment, monitoring, reporting and oversight.
2. Experience in leading outsourcing programs, vendor management, procurement and service management/support.
3. Experience working with cross-functional teams, and a proven track record of managing complex projects and coordinating with multiple parties.
4. Familiarity with contract law and the ability to ensure compliance with legal and regulatory requirements.
5. Experience in developing and implementing performance metrics and conducting vendor assessments.
6. Experience in identifying and mitigating risks associated with outsourcing activities.
7. Certified Outsourcing Professional (COP), Project Management Professional (PMP), or Certified Supply Chain Professional (CSCP) qualifications or similar would be beneficial.
8. Detail-oriented and strong interpersonal skills.
9. Excellent communication skills in German and English.
10. A resident of Germany or an EU passport holder.

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.