Telcoin - Chief Compliance Officer & BSA Officer (TDAB)

• Program ownership and governance • Update, implement, and maintain a risk-based BSA/AML/CFT and OFAC program covering the five pillars: internal controls, independent testing, a designated BSA Officer, training, and customer due diligence including beneficial ownership. • Draft and annually refresh BSA/AML and sanctions policies, procedures, and the Board-approved risk appetite. • Report program status, metrics, and material issues to the Board and senior management at least quarterly. • Own the enterprise BSA/AML and sanctions risk assessment, including products, customers, geographies, delivery channels, and digital asset types. • Customer due diligence • Oversee CIP, KYC, KYB, and enhanced due diligence for retail, institutional, and VASP/counterparty customers. • Set customer risk-rating methodology and periodic review cycles. • Approve onboarding of high-risk customers, including other virtual asset service providers, money services businesses, and foreign correspondents. • Transaction monitoring and blockchain analytics • Oversee fiat and on-chain transaction monitoring, including blockchain analytics tools (e.g., Chainalysis, Sumsub) for wallet screening, exposure analysis, and tracing. • Tune scenarios and thresholds; document model validation and above/below-the-line testing. • Address digital-asset typologies: mixers and privacy tools, darknet markets, ransomware, chain-hopping, bridge exploits, and sanctioned addresses. • Travel Rule and sanctions • Implement FinCEN Recordkeeping and Travel Rule compliance and FATF Recommendation 16 for virtual asset transfers, including counterparty VASP due diligence. • Investigations and regulatory reporting • Manage alert and case investigations; make final SAR filing decisions and ensure timely filing and continuing-activity reviews. • Ensure accurate and timely CTRs, 314(a) responses, 314(b) information sharing, and responses to subpoenas and law enforcement requests. • Stablecoin and custody controls • Establish AML controls for stablecoin issuance, redemption, reserves-related flows, and freeze/blacklist capabilities in coordination with Legal and Engineering. • Ensure custody and wallet-management processes meet recordkeeping and monitoring requirements. • Exams, audits, and training • Serve as primary contact for BSA/AML portions of regulatory examinations and independent audits; own remediation of findings. • Deliver role-based BSA/AML training for the Board, employees, and contractors, with tailored digital asset content. • Evaluate and oversee third-party compliance vendors and partner-bank or program-manager arrangements. • Team leadership and scaling • Build, staff, and lead the financial crimes compliance team; set QA standards and KPIs. • Design a compliance operating model that grows with the business, and plan staffing, tooling, and process needs ahead of growth in customers, transaction volumes, products, and jurisdictions. • Develop talent through clear career paths, succession planning and ongoing professional development. • Partner with Product and Engineering to embed compliance controls into new products before launch. • Budget and financial management • Own the compliance function’s P&L and annual budget, covering headcount, technology, blockchain analytics and screening vendors, independent testing, and training. • Build business cases for compliance investment, with cost, benefit, and risk-reduction analysis, and present them to senior management and the Board. • Track compliance unit costs, such as cost per onboarded customer and per investigated alert, and find efficiencies as volumes grow. • Work with Finance and business leaders to reflect compliance costs and risks in product pricing, new-market entry, and partnership decisions. • Negotiate and manage vendor contracts to get value while meeting regulatory standards.