OnHires - Chief Compliance Officer / BSA Officer
Requirements
• 7+ years of BSA/AML compliance experience in a US-regulated financial institution: MSB, money transmitter, bank, broker-dealer or regulated fintech. • At least 3 years as a designated BSA Officer, Deputy BSA Officer or equivalent with filing authority. A CCO title is not required, but ownership at that level is. • Hands-on programme ownership at a crypto exchange, VASP, crypto-native MSB or payments/fintech MSB. This means execution, not advisory work only. • Deep working knowledge of the BSA/FinCEN MSB regime: 31 CFR Parts 1010 and 1022, SAR and CTR filing, the Funds Transfer and Travel Rules, MSB registration, and FIN-2019-G001. • Direct experience drafting and filing SARs. • Experience preparing for and responding to examinations, independent reviews or sponsor-bank due diligence. • A clear track record of holding filing, exit or programme-adequacy positions under commercial pressure. • Hands-on use of AI tools in compliance work, such as alert triage, drafting support or risk assessment. • Fluent professional English, with writing that stands up to regulator and Board review without editing. • US-based, with the right to work in the US without sponsorship, and willing to be named as BSA Officer to FinCEN and banking partners. A background check is required. • Previous BSA Officer role at a crypto exchange, VASP or crypto-native MSB. • Hands-on blockchain analytics experience: Chainalysis, Elliptic, TRM, Scorechain or equivalent. • Direct experience with an IRS BSA examination or a FinCEN inquiry. • Sponsor-bank or banking-partner relationship management for an MSB. • Visa/Mastercard crypto programme and acquirer compliance exposure. • State money transmitter licensing experience. • Experience presenting to a Board, audit committee or regulator. • Exposure to cross-border compliance in the EU (MiCA), UK or Canada. • CAMS, CCAS, CFE, CRCM or a comparable qualification. • What’s on offer • What’s on offer • A statutory role with real authority, direct Board access and documented independence. • Real ownership: you run the US programme and shape how it supports the company’s growth. • A remote setup within the US, with periodic in-person time at the European HQ.
Responsibilities
• BSA/AML and OFAC programme: policies, procedures, enterprise-wide risk assessment, training and alignment with the group compliance framework, including where US law requires a stricter control. • BSA/AML and OFAC programme: • Monitoring and investigations: fiat and on-chain transaction monitoring, alert disposition, investigation standards and case documentation. • Monitoring and investigations: • SAR decisions: drafting, approving and filing SARs within the 30-day timeline, continuing-activity reviews, and SAR confidentiality. • SAR decisions: • Sanctions: • Information requests: 314(a) responses, subpoenas and law-enforcement requests, and 314(b) information sharing. • Information requests: • Customer and partner risk: KYC/EDD standards, customer risk rating, approval of high-risk and PEP relationships, and exit decisions. • Customer and partner risk: • Vendor oversight: due diligence, configuration and performance of KYC, screening and blockchain-analytics vendors. • Vendor oversight: • Product review: BSA/OFAC assessment of new products, payment methods and partner integrations before launch. • Product review: • Examinations and assurance: IRS BSA examinations, FinCEN inquiries, sponsor-bank audits and the independent review, with evidence-based remediation of findings. • Examinations and assurance: • Registration and governance: FinCEN MSB registration and Board reporting on programme status, filings, findings and emerging risk. • Registration and governance:
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