The FCM Director will serve as the primary liaison to regulatory authorities, ensure adherence to 17 CFR § 3.3 statutory duties, oversee market surveillance for event contracts, and partner directly with Product, Engineering, and Operations teams to build scalable, automated controls in a fast-paced fintech environment. The FCM Director will report to Chief Compliance Officer, Crypto Derivatives North America & Board of Directors
Responsibilities:
- Design, implement, and maintain a compliance program meeting all requirements under the Commodity Exchange Act (CEA), CFTC regulations (including 17 CFR Part 1, Part 3, and Part 166), and NFA rules.
- Author and submit the mandatory Annual Report to the CFTC and the Board of Directors pursuant to 17 CFR § 3.3.
- Serve as the primary point of contact for the CFTC and NFA during examinations, audits, inquiries, and regulatory filings.
- Advise executive leadership and the Board of Directors on regulatory developments, rule changes, and compliance risks related to event contracts and prediction markets.
2. Prediction Market & Trade Surveillance
- Establish and oversee a comprehensive market surveillance program to detect, investigate, and prevent market manipulation, spoofing, wash trading, insider trading, or abusive trading practices in event contract markets.
- Establish protocols to manage novel regulatory issues unique to prediction markets, including contract outcome settlement verification, governance on event determination, and restrictions on trading by prohibited insiders or conflicted parties.
- Monitor order flow, account activities, and position limits across customer accounts in real time.
3. Financial Crimes, AML & Customer Onboarding
- Oversee the FCM’s Anti-Money Laundering (AML), Know Your Customer (KYC), and Customer Identification Program (CIP) policies in accordance with the Bank Secrecy Act (BSA) and NFA Rule 2-9.
- Direct transaction monitoring, sanctions rescreening (OFAC), risk rating methodologies, and suspicious activity reporting (SARs).
- Maintain customer protection frameworks, including rules governing the segregation of customer funds (CFTC § 1.20) and capital adequacy monitoring.
4. Operations, Product & Technical Integration
- Collaborate with Product, Engineering, and Operations teams to embed automated compliance and surveillance controls into platform workflows.
- Review and approve promotional materials, marketing collateral, website content, and disclosures in compliance with NFA Rule 2-29.
- Oversee complaint handling, customer communications, recordkeeping, and supervisory controls under NFA Rule 2-9.
Required Experience:
- 5+ years of senior compliance experience within a CFTC-regulated entity (FCM, DCM, DCO, or Swap Dealer) or financial regulatory agency (CFTC, NFA, SEC, FINRA).
- Deep understanding of the Commodity Exchange Act (CEA), CFTC regulations, NFA rules, and standard derivatives market structures.
- Hands-on experience designing and operating compliance monitoring, AML/KYC workflows, and market surveillance programs.
- Preferred: Prior registration or qualification to serve as an FCM Chief Compliance Officer under 17 CFR § 3.3
- Bachelor’s Degree in Finance, Business, Law, or a related field (J.D. or Master’s degree preferred).