Chief Compliance Officer, US Regulated Entities

About Bullish

Bullish is an institutionally focused global digital asset platform that provides market infrastructure and information services. These include: Bullish Exchange – a regulated and institutionally focused digital assets spot and derivatives exchange, integrating a high-performance central limit order book matching engine with automated market making to provide deep and predictable liquidity. Bullish Exchange is regulated in Germany, Hong Kong, and Gibraltar. CoinDesk Indices – a collection of tradable proprietary and single-asset benchmarks and indices that track the performance of digital assets for global institutions in the digital assets and traditional finance industries. CoinDesk Data – a broad suite of digital assets market data and analytics, providing real‑time insights into prices, trends, and market dynamics. CoinDesk Insights – a digital asset media and events provider and operator of Coindesk.com, a digital media platform that covers news and insights about digital assets, the underlying markets, policy, and blockchain technology.

Reports to: Vice President, Compliance

Position Overview

This is a senior leadership role with unique breadth: serving as the Chief Compliance Officer for our US spot trading entity - Bullish US Operations, LLC, our expanding derivatives business, and our tokenized securities endeavors. The successful candidate will own the full US compliance program across digital‑asset exchange, futures/derivatives, and securities business lines — and will be a critical voice in shaping how Bullish grows its US regulated footprint.

This role is ideal for a compliance leader who has operated at the intersection of CFTC/NFA and SEC/FINRA regulation and is energized by the challenge of building and scaling compliance infrastructure in a dynamic digital‑asset environment.

Responsibilities

Bullish US Operations, LLC (BUSO)

• Maintain and enhance BUSO's compliance program, policies, and procedures in accordance with applicable federal and state law.
• Oversee AML/BSA/OFAC programs, including KYC onboarding, transaction monitoring, and SAR filing obligations.
• Serve as primary compliance liaison with state and federal regulators with jurisdiction over BUSO's digital‑asset exchange activities.
• Manage regulatory examinations, inquiries, and enforcement matters relating to BUSO.

US Broker‑Dealer

• Build and lead the broker‑dealer compliance program from the ground up, including development of WSPs, supervisory controls, and FINRA‑required procedures.
• Serve as registered Chief Compliance Officer (Series 14 or equivalent) with FINRA.
• Manage FINRA examinations, 8210 requests, and regulatory inquiries.
• Ensure compliance with SEC and FINRA rules applicable to digital‑asset securities activities, including Reg BI, AML, and record‑keeping.
• Work closely with legal counsel on broker‑dealer licensing, disclosure, and product approval processes.

Derivatives Trading

• Establish and administer a CFTC‑ and NFA‑compliant compliance program, including written supervisory procedures, training, and annual review obligations.
• Oversee NFA registration requirements, including associated persons (APs) registration and branch office supervision.
• Supervise the application of surveillance and monitoring of trading and order activity as per the FCMs’ provisions.
• Serve as NFA Compliance Liaison and DSRO contact; manage NFA audits and routine examinations.
• Monitor evolving CFTC rulemaking (including digital‑asset derivatives guidance) and update FCM compliance framework accordingly.
• Oversee customer fund segregation compliance and FCM financial condition reporting.

Cross‑Entity & Leadership Responsibilities

• Report directly to the Global Head of Compliance; provide regular compliance reporting to senior management and the Board.
• Build, manage, and mentor a high‑performing US compliance team.
• Develop and deliver compliance training programs tailored to US regulated business lines.
• Collaborate with global compliance leads, legal, technology, and business teams to ensure a coordinated enterprise‑wide compliance posture.
• Lead market surveillance oversight for US regulated venues.
• Identify and manage regulatory risk arising from new products, markets, and business initiatives.

Experience & Qualifications

• 12+ years of progressive compliance experience in US financial services, with meaningful responsibility in a senior or CCO‑level role.
• Deep knowledge of SEC and FINRA rules applicable to broker‑dealers, including supervisory obligations, AML requirements, and registration/licensing frameworks.
• Working knowledge of CFTC and NFA requirements applicable to FCMs, including NFA registration rules, customer protection requirements, and CFTC regulations.
• Experience managing regulatory examinations and enforcement inquiries with CFTC, NFA, SEC, FINRA, or FinCEN.
• Strong understanding of AML/BSA obligations and FinCEN regulatory requirements.
• Demonstrated ability to build and lead compliance teams and programs from the ground up.
• Excellent written and verbal communication skills; ability to engage credibly with regulators, senior management, and the Board.
• J.D. or bachelor's degree in law, finance, business, or a related field.
• Eligibility and willingness to obtain FINRA Series 7, 14 and 24 licenses and NFA Series 3 or other relevant NFA registration.

Preferred

• Experience in or deep familiarity with digital‑asset or cryptocurrency exchange compliance.
• Prior experience at or with a Broker‑Dealer, FCM or similar institution.
• Active NFA Series 3 and/or FINRA Series 7, 14, 24 licenses.
• Experience supporting initial registration or licensing applications with the CFTC, NFA, SEC, or FINRA.
• Familiarity with CFTC‑regulated digital‑asset derivatives guidance and the evolving US crypto regulatory landscape.

Bullish US LLC & CoinDesk Inc. are committed to offering competitive compensation and benefits. The anticipated base salary for this position is $225,000 - $265,000 + discretionary annual target bonus + performance incentives/benefits. Offered salary will be reflective of job related knowledge, skills and commensurate experience.

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.