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 build technology and tools that make earning, investing and transacting more rewarding.

Vision: A world where everyone is empowered to create a better financial future.

Reports to:

Chief Executive Officer - Bullish Gibraltar

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 

• Manage the exchange’s financial compliance programme and support and assist the exchange in meetings its financial crime obligation

• Assess and monitor financial crime risk and the exchange’s compliance with its financial crime obligations

• Escalate issues to Managing Director and, where necessary, update the relevant stakeholders and committees on the financial crime risk profile

• Conduct employee financial crime compliance training and awareness

• Assist management in developing and maintaining an effective financial crime compliance culture

• 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

• Draft and maintain up to date financial crime policies and procedures

• Oversee the operation of the exchange’s ongoing customer due diligence programme

• Ensure that appropriate financial crime compliance controls are in place

• Ensure all internal suspicious activity reports (SARs) received are investigated without delay.

• Ensure that a SAR is submitted to the relevant law enforcement agency in respect of all suspicions that have substance

• 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.

• Assist management in promptly responding to any reasonable request for information from the regulator and/or law enforcement agencies

• Provide guidance to the first line of defence in relation to customer due diligence, the investigation of money laundering alerts or transactions considered suspicious or unusual and develop and/or review monitoring system rules for efficiency and performance.

• Keep the business abreast of relevant financial crime regulatory changes 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

• Recommend any changes to the policies, operating procedures and training, as required, resulting from such regulatory changes

• Implement improvements to the financial crime compliance programme

• 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

Experience & Qualifications 

• German fully qualified lawyer/CPA with an acknowledged professional compliance certification, particularly in AML/CFT have a high chance to be accepted by BaFin

• Sufficient experience compliance position at a banking, cryptocurrency, trading, exchange, blockchain or payments institution with AML/CFT experience;

• Sufficient knowledge of the German AML Act (Geldwäschegesetz – GwG) and the related publications issued by BaFin and European authorities

• Experience in developing, implementing and periodic monitoring of compliance policies, AML/CFT requirements;

• Solid knowledge of relevant IT processes, which is used to conduct suspicious transactions and/or activities by e-banking and cryptocurrency transactions.

• Resident in Germany.

• Fluent in German and English.

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.