Director - Futures Commission Merchant (FCM)

Job description

We are seeking an experienced, strategic, and Director to lead the compliance function for our registered Futures Commission Merchant (FCM). As prediction markets and event contracts emerge as a core modern asset class, this role will be responsible for building, executing, and maintaining a regulatory compliance program aligned with the Commodity Futures Trading Commission (CFTC) and the National Futures Association (NFA). The FCM Director will serve as the primary liaison to regulatory authorities, ensure adherence to 17 CFR § 3.3 statutory duties, oversee market surveillance for event contracts, and partner directly with Product, Engineering, and Operations teams to build scalable, automated controls in a fast-paced fintech environment. The FCM Director will report to Chief Compliance Officer, Crypto Derivatives North America & Board of Directors ### Responsibilities: 1. Regulatory Governance & Mandatory Reporting - Design, implement, and maintain a compliance program meeting all requirements under the Commodity Exchange Act (CEA), CFTC regulations (including 17 CFR Part 1, Part 3, and Part 166), and NFA rules. - Author and submit the mandatory Annual Report to the CFTC and the Board of Directors pursuant to 17 CFR § 3.3. - Serve as the primary point of contact for the CFTC and NFA during examinations, audits, inquiries, and regulatory filings. - Advise executive leadership and the Board of Directors on regulatory developments, rule changes, and compliance risks related to event contracts and prediction markets. 2. Prediction Market & Trade Surveillance - Establish and oversee a comprehensive market surveillance program to detect, investigate, and prevent market manipulation, spoofing, wash trading, insider trading, or abusive trading practices in event contract markets. - Establish protocols to manage novel regulatory issues unique to prediction markets, including contract outcome settlement verification, governance on event determination, and restrictions on trading by prohibited insiders or conflicted parties. - Monitor order flow, account activities, and position limits across customer accounts in real time. 3. Financial Crimes, AML & Customer Onboarding - Oversee the FCM’s Anti-Money Laundering (AML), Know Your Customer (KYC), and Customer Identification Program (CIP) policies in accordance with the Bank Secrecy Act (BSA) and NFA Rule 2-9. - Direct transaction monitoring, sanctions rescreening (OFAC), risk rating methodologies, and suspicious activity reporting (SARs). - Maintain customer protection frameworks, including rules governing the segregation of customer funds (CFTC § 1.20) and capital adequacy monitoring. 4. Operations, Product & Technical Integration - Collaborate with Product, Engineering, and Operations teams to embed automated compliance and surveillance controls into platform workflows. - Review and approve promotional materials, marketing collateral, website content, and disclosures in compliance with NFA Rule 2-29. - Oversee complaint handling, customer communications, recordkeeping, and supervisory controls under NFA Rule 2-9. ### Required Experience: - 5+ years of senior compliance experience within a CFTC-regulated entity (FCM, DCM, DCO, or Swap Dealer) or financial regulatory agency (CFTC, NFA, SEC, FINRA). - Deep understanding of the Commodity Exchange Act (CEA), CFTC regulations, NFA rules, and standard derivatives market structures. - Hands-on experience designing and operating compliance monitoring, AML/KYC workflows, and market surveillance programs. - Preferred: Prior registration or qualification to serve as an FCM Chief Compliance Officer under 17 CFR § 3.3 - Bachelor’s Degree in Finance, Business, Law, or a related field (J.D. or Master’s degree preferred).