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Salary: USD 150,000 - 175,000 / annual
Clear Street is modernizing the brokerage ecosystem with a cloud-native clearing and custody system designed for today's complex, global capital markets. The company is seeking an experienced AML Officer to lead and oversee the Anti-Money Laundering program for digital asset clients.
This is a senior individual-contributor role with program-ownership responsibility across KYC, KYB, and KYT onboarding and ongoing monitoring, as well as end-to-end management of transaction investigations and Suspicious Activity Report (SAR) filing determinations.
Key responsibilities include:
**Program Oversight:** Design, implement, and continuously improve KYC, KYB, and KYT frameworks for digital asset clients in alignment with FinCEN, OFAC, and applicable regulations. Conduct risk-based customer due diligence, including enhanced due diligence (EDD) for high-risk clients and ongoing transactional due diligence. Own ongoing monitoring workflows including periodic reviews, triggered reviews, and adverse media screening. Develop and maintain risk-based KYT policies governing transaction monitoring thresholds, risk scoring methodologies, and escalation protocols. Collaborate with Onboarding, Sales, and Legal to ensure client lifecycle processes are compliant, efficient, and scalable.
**Transaction Investigations & SAR Filing:** Lead the end-to-end transaction investigation process including triage, investigation, escalation, and disposition of alerts from automated monitoring systems. Make well-reasoned, documented SAR filing determinations in compliance with BSA/FinCEN requirements, including timely preparation, review, and submission of SAR narratives. Establish and manage a robust case management workflow with clear SLAs, documentation standards, and quality-control checkpoints. Identify typologies, patterns, and emerging risks in digital asset transaction activity to proactively refine investigation playbooks and alert logic. Interface with law enforcement and regulators in response to subpoenas and information requests.
**Blockchain Analytics:** Serve as the firm's subject-matter expert for Chainalysis (KYT, Reactor, Business Data), driving implementation, configuration, and ongoing optimization. Calibrate risk scoring models, custom alert rules, and exposure thresholds within Chainalysis to reflect the firm's risk appetite and client profile. Partner with Technology and Operations to ensure seamless integration of Chainalysis outputs into broader transaction monitoring and case management infrastructure. Monitor Chainalysis product updates and blockchain analytics developments, recommending program enhancements. Evaluate and integrate supplementary blockchain analytics tools (e.g., Elliptic, TRM Labs) as the program matures.
The role requires 4 days per week in-office presence in New York.
**Requirements:**
**Required:**
- Minimum 5 years of AML compliance experience with at least 5 years specifically focused on digital assets / virtual asset service providers (VASPs)
- Hands-on, practitioner-level expertise with Chainalysis products (KYT and Reactor required; Business Data a strong plus), including implementation, configuration, alert rule-writing, and risk calibration (mandatory requirement)
- Deep understanding of BSA, FinCEN regulations (including the NPRM for unhosted wallets), OFAC sanctions programs, and FATF guidance as applied to digital assets
- Demonstrated experience conducting complex transaction investigations in a digital asset context and drafting SAR narratives
- Proven ability to build or materially enhance an AML program, including policy and procedure development
- Strong analytical skills with the ability to interpret on-chain data, entity exposure, and transaction flow in the context of AML risk
- Excellent written and verbal communication skills; ability to document complex investigations clearly and present to senior stakeholders
**Preferred:**
- Global AML experience across multiple jurisdictions (EU/MiCA, UK FCA, APAC, UAE/DFSA, or similar)
- Experience supporting regulatory examinations or enforcement matters in the digital asset context
- Prior experience at a prime broker, FCM, exchange, or custodian serving institutional digital asset clients
- Knowledge of DeFi, NFT, and cross-chain bridging risk typologies
