Head of Compliance and MRLO, Germany

At Coinbase, our mission is to, and we couldn’t do this without hiring the best people
We’re a group of hard-working overachievers who are deeply focused on building the future of finance and Web3 for our users across the globe, whether they’re trading, storing, staking or using crypto
Know those people who always lead the group project? That’s us

There are a few things we look for across all hires we make at Coinbase, regardless of role or team
First, we look for candidates who will thrive in a like ours, where we default to trust, embrace feedback, and disrupt ourselves
Second, we expect all employees to commit to our to our work
Finally, we seek people who are excited to learn about and live crypto, because those are the folks who enjoy the intense moments in our sprint and recharge work culture
We’re a remote-first company looking to hire the absolute best talent all over the world

Ready to #LiveCrypto? Who you are:

• You’ve got positive energy
  You’re optimistic about the future and determined to get there
   
• You’re never tired of learning
  You want to be a pro in bleeding edge tech like DeFi, NFTs, DAOs, and Web 3
  0
   
• You appreciate direct communication
  You’re both an active communicator and an eager listener – because let’s face it, you can’t have one without the other
  You’re cool with candid feedback and see every setback as an opportunity to grow
  
• You can pivot on the fly
  Crypto is constantly evolving, so our priorities do, too
  What you worked on last month may not be what you work on today, and that excites you
  You’re not looking for a boring job
  
• You have a “can do” attitude
  Our teams create high-quality work on quick timelines
  Owning a problem doesn’t scare you, but rather empowers you to take 100% responsibility for achieving our mission
  
• You want to be part of a winning team
  We’re stronger together, and you’re a person who embraces being pushed out of your comfort zone
  

CB Germany GmbH is licensed as a crypto custodian by the German Federal Financial Supervisory Authority, BaFin, under firm reference number 10158674, and provides crypto services to German retail and institutional customers

Coinbase Germany is committed to deterring illicit activities, protecting the business, protecting the digital assets and financial services communities at large from exploitation by criminals and complying fully with the European and German regulation, economic and trade sanctions (“Sanctions”) and all other national and international regulations applicable to the regulatory authorisation held by Coinbase Germany, as a Crypto custody Financial Institution registered with the German Federal Financial Supervisory Authority (“BaFin”)

The Head of Compliance and MLRO will have overall responsibility for the establishment and maintenance of effective anti-money laundering (AML) and counter-terrorist financing (CTF) policies and procedures, systems and controls
The Head of Compliance in Germany will report to the Head of Compliance for Core Markets and will be based in Germany, with a dotted reporting line to the Board of Coinbase Germany
This person will collaborate with the relevant teams operating under the Global AML program both domestically and internationally and will serve as the central point of contact for senior leadership on all AML program related matters
The role will assist senior compliance leadership in the coordination of KYC/Onboarding, Investigations and Compliance Tools and Risk Analytics teams, and will provide a centralized line of sight into the overall AML program
The role will require extensive cross functional collaboration and frequent third party and regulator interactions
 

What you’ll be doing (ie
job duties):

The Head of Compliance / MLRO, with assistance from the Compliance team, is responsible for: 

-Ensuring compliance with German regulatory requirements;-Maintaining the Compliance and AML Programmes, including: -Drafting, implementing and maintaining the Programme’s related procedures;  -Reviewing and updating the risk assessment at least annually or as otherwise required; -Updating the Programme as required, for example, when relevant regulatory changes occur or additional guidance from regulating agencies is provided; -Updating the Programme when changes to products and/or services occur; and-Ensuring adequate levels of staffing are in place to implement the Programme
-The creation and development of a uniform undertaking-specific risk assessment or a coordinated series of undertaking-specific risk assessments (section 5 of the  AMLA); -Acting as the nominated officer for the purpose of receiving, assessing and filing suspicious transaction reports (to the FIU through the “goAML” IT application); -Holds the function of the central crime prevention office as per Sec
25h KwG; -Producing, at least on an annual basis, a report on the Company’s AML/CFT activities; -Monitoring the effectiveness of the Programme and AML/CTF compliance and taking corrective action to track and remedy any deficiencies; -Ensuring relevant employees within the Company and outsource service providers receive AML/CTF training and that the Company maintains training and attendance records

The MLRO must ensure the following: 

-The appropriateness and effectiveness of the organisational and work instructions established and of the business and customer-related internal 2Sec
7(5) of the AML German Act 1Sec
7(4) of the AML German Act and Sec
3
2 BaFin‘s AML guidelines Anti-Money Laundering & Counter Terrorist Financing Policy 8 Coinbase Germany-GmbH Internal protection systems of the undertaking (Sect
6 of the AML German Act) by means of risk-based monitoring activities, within the scope of a structured approach
-Ensuring appropriate review any of changes to AML/CTF-related laws, regulations, guidance, or regulatory expectations and ensuring that the Company implements processes to remain in full compliance with its AML/CTF obligations and regulatory expectations; -Ensuring appropriate review of the AML/CTF implications of any new or changed products, services, initiatives, or distribution channels and advising Executive Management on necessary steps to mitigate AML/CTF risk; -Promptly alerting the Board and Executive Management to any material issues of AML/CTF non-compliance, and instituting and monitoring corrective action; -Periodic reporting to the Board and Executive Management on the state of AML/CTF compliance and any significant emerging issues; -Managing regulatory relationships, any inspections or reviews and the examination process in relation to AML/CTF

What we look for in you (ie
job requirements):

• 6+ years experience within Compliance and AML at a Financial Services or Technology company financial institution, fintech, or consulting firm
  
• Strong knowledge of anti-money laundering, counter-terrorist financing, and sanctions risks and regulations  (, German Regulatory requirement, 4MLD, OFAC Sanctions, KYC/CDD Regs, etc
  )
  
• Excellent verbal and written communication skills, as well as project management expertise
  
• Highly organized and adept at managing competing priorities, diverse stakeholder groups, and ambiguity
  
• Strong critical thinker and problem solver, with strong attention to detail
  
• Flexibility and the ability to build relationships with internal stakeholders
  

Position ID:  P30190 

Commitment to Equal Opportunity

Coinbase is committed to diversity in its workforce and is proud to be an Equal Opportunity Employer
  All qualified applicants will receive consideration for employment without regard to race, color, religion, creed, gender, national origin, age, disability, veteran status, sex, gender expression or identity, sexual orientation or any other basis protected by applicable law
Coinbase will also consider for employment qualified applicants with criminal histories in a manner consistent with applicable federal, state and local law
 For US applicants, you may view ,  and  notices by clicking on their corresponding links
  Additionally, Coinbase participates in the  in certain locations, as required by law
 

Coinbase is also committed to providing reasonable accommodations to individuals with disabilities
If you need a reasonable accommodation because of a disability for any part of the employment process, please send an e-mail to accommodations[at]coinbase
com and let us know the nature of your request and your contact information
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