Deputy Chief Compliance Officer / Deputy BSA Officer, Builders Bank & Trust

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Block is pursuing an OCC charter to form Builders Bank & Trust, a proposed uninsured national trust bank. Builders Bank is being organized to exercise fiduciary powers and conduct trust company operations in accordance with the National Bank Act and 12 CFR Part 9. The bank's core activities will include digital asset custody, safekeeping, and related fiduciary services for its clients.

The Role

We are building a compliance program designed to enable Block and support the establishment of Builders Bank. We seek a Deputy Chief Compliance Officer who is builder-focused and can hold the bar to OCC standards without losing the operating tempo that has defined Block since inception. The Deputy Chief Compliance Officer supports the Chief Compliance Officer / BSA-AML (CCO/BSA) Officer in the design, implementation, and ongoing administration of Block Trust Bank’s compliance management system and BSA/AML program. This role is dedicated to the trust bank charter team and is responsible for helping the leadership implement compliance architecture to maintain and ensure that the bank maintains an effective, independent, and well-documented compliance function appropriate for a federally chartered national trust bank supervised by the Office of the Comptroller of the Currency (OCC).

The Deputy CCO is a hands-on compliance leader who assists with day-to-day building and execution of the trust bank’s compliance program, including BSA/AML controls, OFAC sanctions compliance, customer due diligence, transaction monitoring oversight, regulatory change management, compliance testing, issue remediation, and examination readiness. This role works closely with the CCO, Risk Lead, COO, CFO, CISO, Legal, and relevant first-line teams while maintaining appropriate independence from revenue-generating business activities.

You Will

• Support the CCO/BSA Officer in establishing and maintaining the trust bank’s Compliance Management System, including policies and procedures, training, monitoring, testing, issue management, and Board reporting
• Assist in designing, maintaining, and executing BSA/AML policies, procedures, and internal controls consistent with 31 CFR 1020.210
• Support customer identification, customer due diligence, enhanced due diligence, beneficial ownership, and ongoing customer risk rating processes
• Oversee day-to-day compliance operations related to transaction monitoring, alert review, case escalation, SAR investigation support, and FinCEN reporting workflows
• Support OFAC sanctions screening, sanctions escalation, Travel Rule compliance, and digital asset wallet screening processes
• Help implement and tune blockchain analytics tools used for transaction monitoring, wallet screening, typology development, and sanctions risk detection
• Develop and maintain digital asset-specific AML typologies, red flags, and escalation procedures for custody and fiduciary activities
• Coordinate compliance monitoring and testing activities, including tracking of findings, remediation plans, root-cause analysis, and evidence of closure
• Support annual independent BSA/AML audit and compliance testing; help ensure findings are reported, tracked, and remediated
• Assist with OCC examination preparation, document production, management responses, and remediation of supervisory findings
• Support regulatory change management for applicable banking, fiduciary, BSA/AML, OFAC, Travel Rule, and emerging digital asset requirements
• Prepare compliance reporting for the CCO, President & CEO, Board Audit & Risk Committee, and other governance forums

You Have

• 7+ years in compliance, BSA/AML, financial crimes, or regulatory compliance at a federally supervised financial institution or similarly regulated financial services firm
• Strong working knowledge of BSA/AML program requirements, including CIP, CDD/EDD, SAR processes, transaction monitoring, OFAC sanctions screening, and regulatory reporting
• Experience supporting compliance programs subject to OCC, Federal Reserve, FDIC, FinCEN, or state banking regulator examination
• Familiarity with compliance management systems, compliance testing, issue management, regulatory change management, and Board-level reporting
• Experience with digital asset AML risks, blockchain analytics, virtual currency typologies, wallet screening, or Travel Rule compliance
• Demonstrated ability to operate independently, escalate issues appropriately, and maintain compliance function independence from business line objectives
• Strong written and verbal communication skills, including ability to prepare clear compliance documentation for senior management, auditors, and regulators
• Must demonstrate a personal history reflecting responsibility, honesty, and integrity, and satisfy OCC background investigation requirements assessing competence, experience, integrity, and financial ability

Even Better

• CAMS certification strongly preferred
• Prior experience at a trust company, custody bank, digital asset exchange, or digital asset custody provider
• Experience helping build or scale a BSA/AML or compliance program for a de novo bank, trust company, or newly regulated financial institution
• Experience with OCC or FinCEN examinations, independent BSA/AML audits, or remediation of MRAs, MRIAs, consent orders, or similar supervisory findings
• Familiarity with OCC safety and soundness expectations, 12 CFR Part 9 fiduciary requirements, OCC Bulletin 2023-17, and 12 CFR Part 30
• Working knowledge of emerging digital asset regulatory frameworks, including stablecoin, qualified custodian, and digital asset custody requirements

We’re working to build a more inclusive economy where our customers have equal access to opportunity, and we strive to live by these same values in building our workplace. Block is an equal opportunity employer evaluating all employees and job applicants without regard to identity or any legally protected class. We will consider qualified applicants with arrest or conviction records for employment in accordance with state and local laws and “fair chance” ordinances.

We believe in being fair, and are committed to an inclusive interview experience, including providing reasonable accommodations to disabled applicants throughout the recruitment process. We encourage applicants to share any needed accommodations with their recruiter, who will treat these requests as confidentially as possible. Want to learn more about what we’re doing to build a workplace that is fair and square? Check out our I+D page.

While there is no specific deadline to apply for this role, U.S. roles are typically open for an average of 55 days before being filled by a successful candidate. Please refer to the date listed at the top of this job page for when this role was first posted.