Compliance Officer and MLRO - US (Digital Transfer Agency)

Join the Future of Technology with ZILO™

At ZILO™, we’re redefining what’s possible in technology. ZILO™ is the UK-based FinTech specialising in global asset and wealth management software, designed to scale and transform businesses of all types using our own developed AI Technology.

Our mission is to digitalise the future of the global asset management industry. We are a team of experts with decades of combined experience at leading firms globally, who thrive in fast-paced environments and want to shape the future of technology. Every individual plays a key role in driving progress and making a real impact. We continuously strive to innovate and improve.

About the role:

This role owns compliance for ZILO’s registered transfer agent in the United States. It covers the Section 17A and 17Ad rule set and the registrant’s standing with the SEC, and it is the designated anti-money laundering officer, owning the Bank Secrecy Act programme, the customer identification programme and suspicious activity reporting. The holder sets the compliance standard for the US line, writes the positions the registrant relies on, and is the person the regulator deals with on how that standard is met.

The role carries both the regulatory compliance and the financial crime mandate for the US entity, and is expected to be direct about capacity, escalating where the workload or an independence requirement means a task should sit elsewhere.

Investor eligibility is enforced at the point of transaction through verifiable credentials that ZILO issues and maintains. The role owns the compliance position behind that: what each credential asserts, that those conditions reflect what the rules require, that eligibility is withdrawn when an investor’s status changes, and that the whole position is documented in a form that can be explained to a regulator and evidenced in practice.

Key Responsibilities:

• Transfer Agent Registration and Standing
• Own SEC transfer agent registration and the Form TA-1 and TA-2 cycle, including amendments as officers, control persons or activities change.
• Own the written supervisory procedures for the registrant and keep them aligned to what the operation actually does.
• Own SEC examination readiness: the record set, the walkthroughs, the control evidence and the narrative that explains a digital-native register to an examiner.
• Own the annual study and evaluation of internal accounting control under Rule 17Ad-13, and ensure it reaches the technology layer rather than stopping at the operational one.
• Own the custody and activity perimeter position – that ZILO holds no client money, fund units, tokens or private keys – and defend it in writing.
• AML and Financial Crime
• Act as the designated AML officer for the fund programme, owning policy, risk assessment, procedures, training and independent testing coordination.
• Own suspicious activity report investigation, decision and filing with FinCEN.
• Oversee the customer identification programme, ongoing due diligence, and sanctions and PEP screening for US investors.
• Oversee transaction monitoring across the fiat and digital asset legs, and own the wallet freeze and unfreeze position where a financial crime trigger arises.
• Rule Compliance and Control Ownership
• Own compliance with the 17Ad rule set as it applies to turnaround, recordkeeping, the control book, aged record differences, safeguarding and instruction authentication.
• Own the Regulation S-P position, including safeguarding of investor information and incident response and breach notification.
• Own the conflicts of interest register, the financial crime prevention procedures covering fraud, bribery and tax evasion, and the whistleblowing channel.
• Own the mapping of the conditions attaching to comparable no-action and exemptive relief in this product area, and track whether the model stays within them.
• Second Line Oversight
• Provide second line challenge to the operational processing delivered by the UK hub for the US line, including a compliance monitoring programme with its own testing.
• Own external service-provider oversight from the compliance side, including the boundary that places the distribution partner outside supplier oversight while keeping the custodian inside it.
• Report to the COO, to the ZILO US board and to the fund board on compliance and financial crime matters.\

Regulatory Accountability

• Exchange Act section 17A(c) and section 3(a)(25); Rules 17Ac2-1 and 17Ac2-2 – registration and Form TA-1 / TA-2.
• Rules 17Ad-6 and 17Ad-7 – recordkeeping creation and retention.
• Rule 17Ad-12 – safeguarding of funds and securities.
• Rule 17Ad-13 – annual study and evaluation of internal accounting control.
• Rule 17Ad-15 – instruction authentication and signature guarantee standards.
• Regulation S-P – safeguarding investor information and incident response.
• Bank Secrecy Act, 31 U.S.C. 5318; USA PATRIOT Act section 326; 31 CFR 1024 – designated AML officer, CIP and SAR obligations.
• OFAC sanctions obligations, including as they apply to wallet addresses and counterparties.

Essential

• Senior compliance experience in a US SEC-registered transfer agent, fund administrator or comparable registrant, with direct ownership of the 17Ad rule set.
• Direct experience of SEC examination, including preparing a registrant for one and responding to findings.
• Prior designated AML officer experience under the Bank Secrecy Act, including SAR filing decisions.
• Experience owning Form TA-1 and TA-2 and the registration lifecycle.
• Experience of the annual internal accounting control study under Rule 17Ad-13.
• The judgement to form and defend a written regulatory position on a novel model, and to say when a position is not defensible.
• Strong written communication – this role produces the documents the SEC will read.
• Eligible to be fingerprinted and submitted for an FBI criminal history record check through an approved channeler under Rule 17f-2, which is a condition of appointment.

Desirable

• Exposure to tokenised securities, digital assets or DLT-based settlement, and to the transfer agent versus clearing agency boundary question.
• Familiarity with verifiable credentials or on-chain eligibility enforcement as a compliance control.
• Experience of a transfer agent registration from a standing start.
• Experience overseeing an offshore or intra-group operational provider from a US registrant.
• Legal qualification or prior regulatory experience.

Skills and Attributes

• Regulatory accountability – personally answerable for the registrant’s standing, and comfortable with that.
• Independence – able to reach a SAR decision or a perimeter position without seeking operational comfort first.
• Intellectual honesty – will say when the counsel position has not yet been reached, rather than proceeding as though it has.
• Capacity awareness – will flag when the combined role has become too much for one person rather than absorbing it silently.
• Attention to detail – a high standard of accuracy in processing, documentation and control evidence, recognising that errors on a register carry direct investor consequences.
• Adaptability – comfortable in a growth-stage environment where not every process or answer yet exists, and willing to help build what is missing.
• Clear communicator – able to explain operational and regulatory matters plainly to colleagues, auditors, counterparties and regulators.

Compensation: details on application. The package comprises a competitive base salary.

Comprehensive US benefits package including medical cover, a 401(k) plan, paid time off and US public holidays. Full details on application.