Compliance Officer and and Money Laundering Reporting Officer (MLRO)
AI Summary
The Compliance Officer and MLRO leads regulatory compliance and financial crime defense for CEX.IO’s Bermuda entity, acting as the main interface with the Bermuda Monetary Authority and managing AML/ATF policies, SAR filings, sanctions screening, and blockchain analytics.
About this role
We are seeking a Compliance Officer and Money Laundering Reporting Officer (MLRO) in Bermuda to lead the regulatory compliance and financial crime defence for our Bermuda-regulated entity.
In this dual, BMA-approved function, you will act as the core guardian of our operational integrity. You will hold ultimate responsibility for ensuring our digital asset operations remain fully compliant with Bermuda's strict Digital Asset Business Act (DABA) 2018 and its comprehensive AML/ATF legislative framework. You will serve as the primary point of contact for the Bermuda Monetary Authority (BMA) and the Financial Intelligence Agency (FIA).
Given the specialised nature of our business, candidates must possess a deep understanding of blockchain data analytics, digital identity protocols, and the unique transaction monitoring challenges inherent to the crypto-asset space.
Key Responsibilities
- Maintain, operationalise, and continuously update the entity’s AML/ATF Policies and Procedures manual in strict accordance with the Proceeds of Crime Act 1997 (POCA) and the AML/ATF Regulations 2008.
- Act as the sole designated officer to receive internal disclosures, evaluate them independently, and promptly file Suspicious Activity Reports (SARs) with the Financial Intelligence Agency (FIA) when required.
- Oversee global sanctions screening operations (against UN, HM Treasury, and Bermuda-specific lists) and implement strict cross-border compliance protocols, specifically enforcing the FATF Travel Rule for virtual asset transfers.
- Establish and manage automated transaction monitoring systems, pairing traditional fiat monitoring with advanced blockchain analytics tools (e.g., Chainalysis, Elliptic, TRM Labs) to detect unusual or high-risk wallet behaviours.
- Design and execute risk-based institutional and retail onboarding flows, ensuring precise Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for politically exposed persons (PEPs) or higher-risk jurisdictions.
- Act as the primary interface for all BMA prudential on-site visits, information requests, and regulatory filings. Lead the preparation of data for the annual BMA AML/ATF returns.
- Oversee and coordinate the mandatory independent annual AML/ATF audit conducted by qualified third parties, systematically addressing and remediating any identified gaps.
- Conduct mandatory, regular AML/ATF and sanctions training for the Board of Directors, local executives, and operations staff, incorporating findings from Bermuda's National Risk Assessment (NRA).
Essential Experience & Qualifications
- Relevant education in Law, Business, Finance, or Criminology. Professional compliance certifications (e.g., ACAMS, ICA, or specialised digital asset compliance credentials) are highly required.
- 5+ years of dedicated regulatory compliance and financial crime experience, with at least 2+ years operating as a designated Compliance Officer or MLRO (or deputy) within a BMA-regulated environment, digital asset business (DAB), electronic money institution, or high-volume payment infrastructure.
- Thorough, authoritative working knowledge of Bermuda’s regulatory landscape, specifically POCA, the AML/ATF Regulations, DABA 2018, and the BMA’s relevant anti-money laundering Guidance Notes.
- Direct, hands-on experience utilising blockchain intelligence tools to investigate on-chain flows, flag high-risk mixing protocols, and trace wallet attributions.
- Based in Bermuda (or willing to relocate) to satisfy the BMA’s mandatory physical presence, local direction, and management requirements for licensed digital asset entities.
Skills
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