Job Description

About Bullish

Bullish is an institutionally focused global digital asset platform that provides market infrastructure and information services. These include:BullishExchange– 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.CoinDeskIndices– 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.CoinDeskData- a broad suite of digital assets market data and analytics, providing real-time insights into prices, trends, and market dynamics.CoinDeskInsights– a digital asset media and events provider and operator ofCoindesk.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

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 recordkeeping.

• 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 (WSPs), 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.