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 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