Head of Compliance and MLRO - Germany

  • Coinbase
  • Berlin, Germany
  • Oct 17, 2020

Job Description

Location: Berlin, Germany
Coinbase has built the world's leading compliant cryptocurrency platform serving over 30 million accounts in more than 100 countries. With multiple successful products, and our vocal advocacy for blockchain technology, we have played a major part in mainstream awareness and adoption of cryptocurrency. We are proud to offer an entire suite of products that are helping build the cryptoeconomy, and increase economic freedom around the world.

There are a few things we look for across all hires we make at Coinbase, regardless of role or team. First, we assess whether a candidate demonstrates our values: Clear Communication, Positive Energy, Efficient Execution, and Continuous Learning. Second, we look for signals that a candidate will thrive in a culture like ours, where we default to trust, embrace feedback, disrupt ourselves, and expect sustained high performance because we play as a championship team. Finally, we seek people with the desire and capacity to build and share expertise in the frontier technologies of crypto and blockchain, in whatever way is most relevant to their role.

Read more about our values and culture here.

The Head of Compliance and MLRO for Germany will have overall responsibility for the establishment and maintenance of an effective Compliance Program for Coinbase's German operations, including policies and procedures, exam management, advice on the impact of new regulations and anti-money laundering (AML) and counter-terrorist financing (CTF) systems and controls. The role will encompass Compliance advisory responsibilities, including subject matter expertise on AML/CTF/AB&C, regional regulatory best practices, sales, financial promotions, operations, payments, complaints, systems and controls, governance, risk mitigation, law enforcement and suspicious activity etc.

What you'll be doing (ie. job duties):
  • Lead Compliance input/management of the licence application to the BaFIN for a licence under the German Banking Act (KWG)
  • Maintain all external Germany Compliance relationships with:
    • i) regulators;
    • ii) banking partners;
    • iii) industry working groups; and
    • iv) third party Compliance vendors.
  • Responsible for overall compliance with the provisions under anti-money laundering and counter terrorist financing in German law.
  • Responsible for keeping abreast of legal and regulatory developments in Germany and Europe that could impact Coinbase's business, and for rolling out necessary changes in a timely and cost-effective manner in collaboration with internal stakeholders.
  • Carry out regular assessments of the adequacy of systems and controls to ensure that risks are managed effectively. Ensure that policies are updated to meet changing regulatory and business requirements.
  • Maintain a detailed working knowledge of relevant regulations and be able to summarise brief management concisely. Liaise with other functional divisions to lead or assist on projects to cover Compliance tasks such as documenting decisions and enhancing policies and procedures.
  • Review and approve recommendations on appropriate changes to global business models, practices, controls or processes required to comply with legislative/regulatory changes and best practice. Liaise with business and product teams as appropriate.
  • Manage and develop global relationships with key internal stakeholders and senior management in order to promote a consistent approach to the development and execution of an effective and integrated control environment.
  • Oversee the design, development and roll-out of the Germany Compliance Monitoring Programs for:
    • Mandatory regulatory reporting in accordance with local requirements.
    • Anti-Bribery and Corruption practices.
    • Complaints handling including training and ongoing coordination with relevant stakeholders.
    • The Policy framework (including creating a formal risk matrix).
  • Track all relevant Internal Audit and Regulatory Exam items.
  • Responsible for Compliance training of local employees.
  • Work with the Head of International Compliance, to respond to regulatory comment letters.
  • Manage the Germany integration and implementation of relevant projects e.g. sanctions, onboarding.
  • Proactively participate in internal business committees and working groups.
  • Design an effective 2nd Line of Defence Compliance Monitoring and Testing Framework for the business in order to:
    • Identify regulatory program requirements.
    • Validate compliance against established policies, procedures and applicable rules, standards and regulations.
    • Work with regional Compliance departments to develop regional monitoring and testing programs, including the tracking and reporting of the 1st Line of Defence's remediation of compliance issues.
    • Escalate regulatory compliance issues or material incidents of non-compliance to the Head of International Compliance and Board of Coinbase Germany.
  • Periodic key reporting and notifications both internally and externally as required.

    • Assist in the management and implementation of appropriate AML and CTF policies and procedures.
    • Ensure that AML and CTF requirements are considered as part of the development of new products, or service changes.
    • Maintain up to date AML documentation.
    • Assist in the development of reports to the Board on a regular basis detailing the operation and effectiveness of the systems and controls used to combat financial crime.
    • Arrange and assist with regulatory visits and audit inspections.
    • Maintain an internal reporting process for receiving internal Suspicious Activity Reports (SARs).
    • Act as the point of contact regarding AML compliance for the law enforcement agencies, for the authorities responsible for the detection, prevention and elimination of threats, for the German Financial Intelligence Unit and for the supervisory authority.

What we look for in you (ie. job requirements):
  • 7-10 years of experience working in Compliance functions in financial services firms that are regulated by the BaFin.
  • Comprehensive knowledge of financial services regulations; and retail/ institutional level products including:
    • Administrative regulations issued by the BaFin to implement the German Securities Trading Act requirements.
    • The duties, responsibilities and powers of the Compliance function and Compliance officers, trading supervision and the provisions of Section 3 of the German Securities Trading Act
    • Payment services/e-money experience is beneficial but not required.
    • Experience in managing, developing and administering internal controls and processes.
    • Ability to work collaboratively with a broad range of business functions, with an emphasis on senior management.
    • A professional compliance or finance qualification, and membership of a recognised professional body, would be advantageous but not a prerequisite.
  • Expertise when it comes to regulatory knowledge in Germany and the broader EU region.
  • Leadership - voice concerns, challenge and help implement a roadmap for Europe in partnership with colleagues in London and Dublin.
  • Ability to thrive in a fast-paced remote environment.
  • Commitment to Diversity
  • Demonstrated ability to generate and execute strategies across a global organisation.
  • Skilled at executing large, multi-functional and cross-organisational assignments that require in-depth analysis.
  • Ability to develop, foster and maintain effective working relationships with diverse groups of people within the organisation as well as with external stakeholders and vendors.
  • Leadership and key stakeholder engagement skills and experience required.
  • Exceptional interpersonal skills and the innate ability to work unsupervised in a structured manner.
  • Keen interest in digital currencies.
  • Related bachelor's level degree required.

Coinbase is committed to diversity in its workforce and is proud to be an equal opportunity employer and to review all of our job postings to minimize biased language. Coinbase does not make hiring or employment decisions on the basis of race, color, religion, creed, gender, national origin, age, disability, veteran status, marital status, pregnancy, sex, gender expression or identity, sexual orientation, citizenship, or any other basis protected by applicable local, state or federal law. Coinbase will also consider for employment qualified applicants with arrest and conviction records in a manner consistent with San Francisco's Fair Chance Ordinance and similar local laws.

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