High Risk Ongoing Due Dilligence (ODD) Analyst

Role Overview

The High Risk ODD Analyst is responsible for conducting continuous monitoring and periodic reviews of high-risk retail customers, transactions, and entities within a cryptocurrency or digital assets environment. The role ensures ongoing compliance with AML/CFT regulations and internal policies by performing risk-based ongoing due diligence on retail accounts with elevated risk profiles, detecting emerging risks, and ensuring timely remediation actions.

Key Responsibilities

Ongoing Monitoring & Periodic Reviews

• Conduct periodic High Risk ODD reviews on existing high-risk retail customers, including PEPs, sanctioned individuals/entities, and customers in high-risk jurisdictions


• Perform continuous transaction monitoring and behavioral analysis to identify changes in risk profile or suspicious activity patterns


• Review and analyze crypto transactions, wallet activities, and counterparty relationships using blockchain analytics tools (e.g., Elliptic, Chainalysis, TRM)


• Monitor for changes in customer circumstances, employment status, business activities, or geographic exposure

Risk Assessment & Documentation

• Reassess customer risk ratings based on updated information, transaction behavior, and external risk factors


• Analyze ongoing source of funds (SOF), transaction patterns, wallet behavior, and exposure to high-risk counterparties


• Review and validate changes in customer information, employment details, and account usage patterns


• Track sanctions screening results, adverse media, and reputational risks on an ongoing basis

Reporting & Escalation

• Draft comprehensive ODD reports with updated risk assessments and actionable recommendations (continue, enhance monitoring, restrict, or exit)


• Escalate material changes in risk profile, suspicious patterns, or regulatory concerns to Senior Compliance and MLRO


• Identify and escalate potential suspicious activity (SAR/STR triggers) discovered during ongoing reviews


• Maintain accurate and timely records in internal case management systems

Compliance & Quality Standards

• Adhere to ODD review schedules, SLAs, and internal Standard Operating Procedures (SOPs)


• Ensure all ongoing due diligence activities meet regulatory requirements and internal QA standards


• Support internal and external audits by providing documentation and case rationale


• Stay current on regulatory updates, emerging typologies, and industry best practices

Required Skills & Qualifications

• 2–4+ years of experience in AML Compliance, Financial Crime, or Ongoing Due Diligence, preferably in crypto, fintech, or retail banking


• Strong knowledge of AML/CFT regulations, ongoing CDD requirements, and risk-based monitoring frameworks


• Understanding of sanctions frameworks (OFAC, UN, EU, HMT), PEP definitions, and adverse media screening


• Solid understanding of blockchain technology, cryptocurrency wallets, transaction flows, and on-chain analysis