Lead, Compliance (SAR Investigations)

About the Company

Gemini is a global crypto and Web3 platform founded by Tyler Winklevoss and Cameron Winklevoss in 2014. Gemini offers a wide range of crypto products and services for individuals and institutions in over 70 countries.

Crypto is about giving you greater choice, independence, and opportunity. We are here to help you on your journey. We build crypto products that are simple, elegant, and secure. Whether you are an individual or an institution, we help you buy, sell, and store your bitcoin and cryptocurrency. 

At Gemini, our mission is to unlock the next era of financial, creative, and personal freedom.

The Department: Compliance

Compliance at Gemini is a team dedicated to managing the next generation of financial crime prevention in a complex and evolving regulatory environment.  We are a diverse group of technology, legal, and operational professionals who develop new approaches to solving classic problems using cutting edge tools and processes.

The Role: Lead, Compliance (SAR Investigations)

In this role, you will lead a team of experienced investigators responsible for critical functions within the Compliance and the AML/BSA program. You will have responsibilities including, but are not limited to, advising on the analysis and adjudication of escalated events of unusual activity, reviewing and ensuring the high quality of Gemini’s Suspicious Activity Report (“SAR”) filings, filing Gemini’s SARs with the relevant regulators, leveraging intelligence gained from business-as-usual activities to develop enhancements to the Compliance program and other critical components/development of the compliance program that may arise from time to time. This position will have frequent interaction with firm senior management, third party vendors/auditors, and the Chief Compliance Officer.

Gemini’s Compliance team is constantly evolving and developing new operations and controls. In this role, you will contribute to and lead that development as an integral part of the Investigations Team.  

Responsibilities:

• Conduct investigations of customer activity to determine whether such activity warrants reporting or other action. 
• Review team escalations for SAR filings and ensure all SARs meet the high expectations driven by Gemini’s compliance-first ethos.  
• File Gemini US SARs, including providing SAR metrics with other compliance stakeholders on a regular and ad hoc basis. 
• Manage the SAR filing workflow to consistently meet regulatory and internally defined deadlines.
• Advise compliance colleagues across the globe on suspicious activity trends observed in escalations. 
• Remain current with industry developments and new BSA/AML rules, regulations and guidance.
• Contribute effective leadership to the Investigations team as an experienced professional and individual contributor, drawing on your diverse skills and knowledge-base to advise team members in their day-to-day responsibilities.  
• Gather information from escalations, different workstreams and sources to develop typologies and recommendations for control enhancements.
• Balance numerous projects, queues and priorities in a fast-paced start-up environment.

Minimum Qualifications:

• BA/BS degree or international equivalent.
• 8+ years of relevant AML-related work experience within the financial services, law enforcement, digital asset services, and/or management consulting space focusing on financial crime and counter-terrorism financing.
• Subject matter expertise in BSA/AML regulations with specific focus on the drafting and preparing of US SAR filings.
• Comfort in a technology-forward company and facility with computer and web-based applications, including Google GSuite, case management systems, and web-based databases.
• Superior writing skills, including the ability to analyze and assess large amounts of information into succinct responses. 
• Ability to work independently.
• Authorization to work in the United States and fluency in English.

Preferred Qualifications:

• Advanced degree/certifications, e.g., JD, CAMS, CFE.
• Familiarity with virtual currencies, digital transfer platforms, analysis of trade data on an exchange, or blockchain tracing/analytics tools.
• Intermediate-level expertise in Microsoft Excel or other database querying programs. 
• Comfort with an ever-changing regulatory and business environment.
• Proven ability to proactively, efficiently, and accurately assess risks in a fast-paced environment.
• Track record of creative problem-solving, excellent written and oral communication skills, and creation of strong and trusted cross-functional relationships. 
• Interest in building the future of compliance and an owner’s mindset to your work.

• Competitive starting salary
• A discretionary annual bonus
• Long-term incentive in the form of a new hire equity grant
• Comprehensive health plans
• 401K with company matching
• Paid Parental Leave
• Flexible time off

Salary Range: The base salary range for this role is between $122,000 - $170,000 in the State of New York, the State of California and the State of Washington. This range is not inclusive of our discretionary bonus or equity package. When determining a candidate’s compensation, we consider a number of factors including skillset, experience, job scope, and current market data.

In the United States, we have a flexible hybrid work policy for employees who live within 30 miles of our office headquartered in New York City and our office in Seattle. Employees within the New York and Seattle metropolitan areas are expected to work from the designated office twice a week, unless there is a job-specific requirement to be in the office every workday. Employees outside of these areas are considered part of our remote-first workforce. We believe our hybrid approach for those near our NYC and Seattle offices increases productivity through more in-person collaboration where possible.

At Gemini, we strive to build diverse teams that reflect the people we want to empower through our products, and we are committed to equal employment opportunity regardless of race, color, ancestry, religion, sex, national origin, sexual orientation, age, citizenship, marital status, disability, gender identity, or Veteran status. Equal Opportunity is the Law, and Gemini is proud to be an equal opportunity workplace. If you have a specific need that requires accommodation, please let a member of the People Team know.

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