TDAB - Chief Compliance Officer & BSA Officer
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As Chief Compliance Officer and Board-designated BSA Officer at Telcoin Digital Asset Bank (TDAB), you own the Bank's BSA/AML, counter-terrorist financing and OFAC sanctions compliance program across both fiat and digital asset activity. This senior leadership role reports to the Board Risk/Audit Committee and serves as the Bank's primary BSA/AML contact for the state banking regulator, FinCEN, OFAC and federal partners. You will build and scale the financial crimes compliance function from the ground up as the Bank establishes operations.
What you'll do
- Update, implement, and maintain a risk-based BSA/AML/CFT and OFAC program covering internal controls, independent testing, designated BSA Officer duties, training, and customer due diligence including beneficial ownership
- Draft and annually refresh BSA/AML and sanctions policies, procedures, and the Board-approved risk appetite
- Report program status, metrics, and material issues to the Board and senior management at least quarterly
- Own the enterprise BSA/AML and sanctions risk assessment across products, customers, geographies, delivery channels, and digital asset types
- Oversee CIP, KYC, KYB, and enhanced due diligence for retail, institutional, and VASP/counterparty customers
- Set customer risk-rating methodology and periodic review cycles
- Approve onboarding of high-risk customers, including other virtual asset service providers, money services businesses, and foreign correspondents
- Oversee fiat and on-chain transaction monitoring, including blockchain analytics tools such as Chainalysis and Sumsub for wallet screening, exposure analysis, and tracing
- Tune transaction monitoring scenarios and thresholds; document model validation and above/below-the-line testing
- Address digital-asset typologies: mixers and privacy tools, darknet markets, ransomware, chain-hopping, bridge exploits, and sanctioned addresses
- Implement FinCEN Recordkeeping and Travel Rule compliance and FATF Recommendation 16 for virtual asset transfers, including counterparty VASP due diligence
- Run OFAC and global sanctions screening of customers, transactions, and wallet addresses including SDN-listed addresses; manage blocking, rejection, and reporting obligations
- Manage alert and case investigations; make final SAR filing decisions and ensure timely filing and continuing-activity reviews
- Ensure accurate and timely CTRs, 314(a) responses, 314(b) information sharing, and responses to subpoenas and law enforcement requests
- Establish AML controls for stablecoin issuance, redemption, reserves-related flows, and freeze/blacklist capabilities in coordination with Legal and Engineering
- Ensure custody and wallet-management processes meet recordkeeping and monitoring requirements
- Serve as primary contact for BSA/AML portions of regulatory examinations and independent audits; own remediation of findings
- Deliver role-based BSA/AML training for the Board, employees, and contractors, with tailored digital asset content
- Evaluate and oversee third-party compliance vendors and partner-bank or program-manager arrangements
- Build, staff, and lead the financial crimes compliance team; set QA standards and KPIs
- Design a compliance operating model that grows with the business, and plan staffing, tooling, and process needs ahead of growth in customers, transaction volumes, products, and jurisdictions
- Develop talent through clear career paths, succession planning and ongoing professional development
- Partner with Product and Engineering to embed compliance controls into new products before launch
- Own the compliance function's P&L and annual budget, covering headcount, technology, blockchain analytics and screening vendors, independent testing, and training
- Build business cases for compliance investment, with cost, benefit, and risk-reduction analysis, and present them to senior management and the Board
- Track compliance unit costs such as cost per onboarded customer and per investigated alert, and find efficiencies as volumes grow
- Work with Finance and business leaders to reflect compliance costs and risks in product pricing, new-market entry, and partnership decisions
- Negotiate and manage vendor contracts to get value while meeting regulatory standards
What you bring
- A bachelor's degree in finance, criminal justice, law, business or a related field
- 8+ years of BSA/AML compliance experience at a bank, trust company or regulated money transmitter, including 3+ years as a BSA Officer, deputy or program lead
- 2+ years of direct experience with digital assets, virtual currency or a VASP/crypto exchange
- Hands-on experience leading regulatory examinations and remediating findings
- Proven SAR decisioning and investigation management experience
- Working knowledge of the BSA, USA PATRIOT Act, AML Act of 2020, FinCEN CDD Rule, OFAC regulations and FATF virtual asset guidance
- A proven track record of building or scaling a compliance function through significant growth, including owning a departmental budget
- One or more certifications: CAMS, CAMS-FCI, CRCM or CFE
- Authorization to work in the United States
Nice to have
- Advanced digital asset AML certification such as CCAS, CCI, or Chainalysis/TRM investigator certification
- Experience at a de novo bank, with a charter application, or with state trust or digital asset charters
- Experience with stablecoin programs, including issuer-side controls
- A JD, MBA or other advanced degree
- Familiarity with smart contracts, wallet architecture and on-chain data analysis such as SQL against blockchain data
What we offer
- An executive leadership role at a pioneering digital asset bank
- The opportunity to build the Bank's compliance function from the ground up and shape its risk culture
- Direct access to the Board and senior leadership
- Exposure to innovative blockchain and payment technologies
About Telcoin Digital Asset Bank
Telcoin Digital Asset Bank (TDAB) is a Nebraska-chartered digital asset depository institution bringing regulated banking and blockchain-based financial services together, including digital asset custody, stablecoin issuance and redemption, and on-chain payments.
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