AML Officer - NA & Carribean

• →AML Program Leadership: Serve as the senior AML authority for all North American and Caribbean entities; own the design and execution of the AML/CTF and sanctions compliance program for these entities.
• →Policy & Procedure Authority: Develop and maintain AML/CTF and sanctions policies and procedures across all regional entities; ensure policies reflect current regulatory requirements, enforcement trends, and the firm's evolving business activities.
• →Risk Assessment: Lead the development and annual refresh of enterprise-wide AML risk assessments; identify inherent and residual risk across customer, product, geographic, and channel dimensions; present findings and risk ratings to senior management and boards. Lead control enhancement and remediation strategy for self-identified issues.
• →Program Governance: Establish and maintain program governance frameworks including issue management, findings tracking, escalation protocols, and management reporting; ensure open items are remediated on schedule and program gaps are surfaced proactively.
• →Senior Management & Board Reporting: Prepare and deliver periodic AML program reports to senior management, boards, and governance committees across entities; provide clear, data-driven assessments of program health, risk posture, and remediation status.

• Regulatory Relationship Management: Serve as the primary AML point of contact for regulators across the region, including FinCEN, NYDFS, FINTRAC, BVIFSC, and CIMA.
• Examination Preparation & Response: Lead preparation for regulatory examinations and internal/external audits; coordinate document production, draft cover narratives, manage examiner meetings, and oversee remediation of examination findings.
• Regulatory Reporting Oversight: Oversee the timely and accurate filing of required regulatory reports across jurisdictions, including SARs (FinCEN), STRs (FINTRAC), and equivalent suspicious transaction reporting obligations in BVI and Cayman; review and approve material filings.
• Regulatory Change Management: Monitor and assess emerging AML regulatory developments across all applicable jurisdictions; evaluate impact on the firm's program and business activities; translate regulatory changes into actionable policy and procedure updates.

• United States - Federal: Maintain deep expertise in U.S. federal AML obligations under the Bank Secrecy Act (BSA), USA PATRIOT Act, FinCEN regulations, and OFAC sanctions requirements; oversee program components including CIP, CDD, EDD, transaction monitoring, SAR filing, and recordkeeping for U.S.-domiciled entities.
• United States - New York (NYDFS): Manage compliance with NYDFS-specific requirements applicable to Cumberland's New York licensed entity, including NYDFS Part 504 (Transaction Monitoring and Filtering Program requirements), BitLicense obligations under 23 NYCRR 200, and annual certification obligations; serve as the NYDFS AML contact and manage examination and inquiry responses.
• Canada (FINTRAC): Oversee AML/CTF compliance for DRW's Canadian operations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC regulations; ensure obligations are met with respect to client identification, beneficial ownership, transaction reporting, and STR filing; maintain FINTRAC registration and manage examination readiness.
• British Virgin Islands (BVIFSC): Oversee AML/CTF and sanctions compliance for BVI-domiciled entities under the Proceeds of Criminal Conduct Act, the Anti-Money Laundering and Terrorist Financing Code of Practice, and applicable BVIFSC guidance; manage BVIFSC relationship, examination responses, and STR obligations to the BVI Financial Intelligence Agency (FIA); ensure policies reflect 2025 BVIFSC inspection findings and updated AML/CTF/sanctions requirements.
• Cayman Islands (CIMA): Maintain program compliance for Cayman-domiciled entities under the Proceeds of Crime Law (PCL), Anti-Money Laundering Regulations (AMLRs), and Guidance Notes on the Prevention and Detection of Money Laundering and Terrorist Financing; ensure obligations are met with respect to customer due diligence, suspicious activity reporting to the Cayman Islands Financial Reporting Authority (CIFRA), and CIMA oversight requirements.

• Escalation Authority: Serve as the final escalation point for complex or sensitive AML investigations, alert dispositions, and SAR/STR filing decisions across all regional entities; provide guidance on novel or high-risk fact patterns.
• SAR/STR Filing Decisions: Review and approve SAR and STR filings across jurisdictions; ensure filings are complete, accurate, timely, and appropriately documented; maintain a filing log and oversee recordkeeping obligations.
• Sanctions Program Oversight: Oversee OFAC and equivalent sanctions screening programs across entities; review and approve responses to potential matches; ensure screening coverage is appropriate for the firm's counterparty and transaction profiles.
• Blockchain Analytics Oversight: Direct the use of blockchain analytics tools (Chainalysis, TRM Labs, or equivalent) within the AML program; ensure alert thresholds, risk scoring, and investigation protocols are calibrated appropriately and reviewed periodically.
• Crypto Financial Crime Typologies: Maintain current, deep knowledge of financial crime typologies specific to digital asset markets; apply typology knowledge to refine the effectiveness of the program.

• Training Program: Develop and deliver AML training programs for compliance staff, operations, the business, and senior management; ensure training is current, jurisdiction-specific where required, and appropriately documented; track completion and maintain training records.
• Cross-functional Engagement: Partner with legal, operations, technology, and trading to ensure AML program requirements are understood and embedded into business workflows; provide timely, well-reasoned guidance on counterparty activity, policy questions, and escalated matter.
• Program Influence Without Direct Authority: Drive program outcomes and accountability across the AML function through influence, expertise, and collaborative engagement; build strong working relationships with AML analysts, operations teams, and business stakeholders to ensure program standards are consistently applied.

• Experience: 10+ years of BSA/AML compliance experience, including at least 3-5 years in a senior AML officer, deputy officer, or equivalent leadership role at a financial institution, digital asset firm, or regulated entity.
• Multi-jurisdictional AML Expertise: Demonstrated, hands-on knowledge of AML/CTF regulatory frameworks across at least two of the following: U.S. federal (BSA/FinCEN/OFAC), NYDFS, Canada (FINTRAC/PCMLTFA), British Virgin Islands (BVIFSC), or Cayman Islands (CIMA); willingness and ability to rapidly develop proficiency across all five jurisdictions.
• Program Design & Ownership: Proven track record of designing, implementing, or materially improving an AML/CTF compliance program at regulated financial institutions; experience owning policies, risk assessments, and governance frameworks.
• Regulatory Engagement: Direct experience preparing for and responding to regulatory examinations, inquiries, or audits; ability to manage examiner relationships professionally and produce high-quality regulatory responses under deadline pressure.
• Investigations & SAR Authority: Experience serving as a SAR/STR review and approval authority; strong judgment on escalation decisions, complex alert dispositions, and novel financial crime typologies relevant to digital asset trading.
• Digital Assets Experience: Prior experience in a virtual currency, crypto trading, or digital asset compliance environment; familiarity with blockchain analytics tools such as Chainalysis and Elliptic and the financial crime risks unique to crypto markets.
• Communication & Executive Presence: Exceptional written and verbal communication skills; demonstrated ability to present complex compliance matters clearly to boards, senior executives, and regulators; experience drafting board-level compliance reports and regulatory submissions. Ability to lead and collaborate efficiently with AML and external resources.
• Judgment & Independence: Sound independent judgment on ambiguous regulatory questions; comfortable operating in fast-moving, high-accountability environments with limited precedent.

• Regulatory Experience: Prior experience as a regulator, examiner, or compliance officer embedded in a regulatory examination process at FinCEN, NYDFS, FINTRAC, BVIFSC, CIMA, or a comparable authority.
• NYDFS Expertise: In-depth knowledge of NYDFS Part 504 certification requirements, BitLicense obligations, and NYDFS examination procedures; prior experience managing a NYDFS examination or enforcement matter.
• Caribbean Jurisdiction Experience: Hands-on experience operating an AML/CTF program under BVI (BVIFSC) or Cayman (CIMA) regulatory frameworks, including familiarity with local legislative requirements, reporting obligations, and examination practices.
• Canada FINTRAC Experience: Direct experience managing a FINTRAC-registered AML compliance program, including registration maintenance and FINTRAC examination readiness.
• Multi-entity Program Management: Experience managing AML programs simultaneously across multiple legal entities, jurisdictions, or business lines with distinct regulatory obligations and risk profiles.
• Sanctions Expertise: Advanced knowledge of OFAC sanctions compliance, including SDN screening, secondary sanctions considerations, and voluntary self- disclosure processes; experience with equivalent sanctions regimes (UN, EU, UK, Canada) a plus.

The annual base salary range for this position is $160,000 to $215,000 depending on the candidate’s experience, qualifications, and relevant skill set. The position is also eligible for an annual discretionary bonus. In addition, DRW offers a comprehensive suite of employee benefits including group medical, pharmacy, dental and vision insurance, 401k (with discretionary employer match), short and long-term disability, life and AD&D insurance, health savings accounts, and flexible spending accounts.