Director, Financial Risk

Reports to:

Position Overview

Bullish is seeking an experienced and strategic Director of Financial Risk to define, implement and oversee the comprehensive risk management framework for our US clearing business.  This framework must ensure compliance with all relevant regulatory requirements for both traditional and digital asset clearing, particularly those related to the prevention of financial default, operational resilience, and the smooth functioning of the clearing system. This role requires an individual with a deep understanding of central counterparty (CCP) risk models, systemic risk mitigation, digital asset risk management and regulatory engagement. Reporting to senior leadership, you will play a critical role in ensuring the stability, security, and compliance of our U.S. derivatives business.

Responsibilities:

Financial Risk Management (Default & Loss Prevention)

• Default Management: Own and implement the Default Management Waterfall procedures, ensuring maintenance of an appropriate pre-funded financial resource package sufficient to cover losses.

• Margin System Oversight: Direct and oversee the development, validation, and calibration of the US clearing risk-based margin models (e.g., VaR or SPAN). Ensure margin is calculated with sufficient frequency to cover the potential loss of participant portfolios to a high degree of confidence, while ensuring digital asset operational characteristics are applied where feasible.

• Stress Testing: Direct the daily, frequent, and extreme stress testing program across all cleared products and market scenarios. Report results and ensure models are adapted based on testing outcomes.

• Liquidity Risk: Oversee the liquidity risk management framework, ensuring maintenance of sufficient liquid resources to manage obligations in an emergency.

Regulatory Compliance and Governance

• Risk Framework Ownership: Develop, maintain, and enforce the written Risk Management Framework and policies, ensuring strict compliance with all applicable regulatory rules, guidelines and principles (including financial resources, risk management, settlement, and transparency).

• Regulatory Liaison: Act as the primary risk contact with all relevant financial regulators. Oversee all internal and external risk audits and examinations.

• New Product Review: Serve as the final approver for the risk profile of all new products or services introduced for clearing, ensuring adequate margin and financial resources are in place before launch.

• Reporting: Prepare and present regular, comprehensive risk reports to the Risk Committee, Board of Directors, and regulators, highlighting key exposures, stress test results, and policy changes.

Operational, Technology, and Resilience Risk

• Operational Resilience: Oversee the framework for operational resilience, including the Business Continuity Plan (BCP) and Disaster Recovery (DR) capabilities. Ensure critical operations can resume within the defined recovery time objectives.

• Cybersecurity Risk: Collaborate with the Chief Information Security Officer (CISO) to manage, monitor, and report on all cybersecurity risks, ensuring system safeguards protect critical infrastructure and data.

• Affiliate Risk: Identify and manage potential risks arising from the activities of any affiliates operating within the Bullish US market infrastructure.

• Enterprise Risk Strategy and Framework: Develop and implement the overall risk management strategy for Bullish's U.S. business, including identifying, assessing, and prioritizing all key risks (operational, financial, regulatory, cybersecurity, market volatility, liquidity, and credit).

• Team Leadership: Lead, mentor, and build a high-performing team of risk professionals, providing guidance and fostering a culture of risk awareness across the organization.

• Risk Mitigation and Controls: Establish and oversee robust risk controls, policies, and procedures to mitigate potential threats. 

• Reporting and Analysis: Conduct regular risk assessments and stress tests. Monitor and analyze key risk indicators (KRIs) and metrics to measure risk exposure and identify emerging risks. Prepare and present detailed reports on risk exposures and performance to senior management and the Board of Directors.

• Cross-Functional Collaboration: Work closely with other departments, including Legal, Compliance, Trading, Operations, and Technology, to ensure a cohesive and integrated approach to risk management and to support new product development.

• Incident Response: Lead incident response and crisis management efforts, ensuring timely resolution and reporting of any risk-related incidents.

Experience & Qualifications:

• Master’s degree in Finance, Economics, Quantitative Methods, or a related field required. Relevant professional certifications (e.g., FRM, PRM, CFA) are highly desirable.

• 10+ years of progressive risk management experience within the financial services industry, with at least 5 years in a senior leadership role at a DCO, major clearing bank (FCM), central bank, or equivalent systematically important financial institution (SIFI). Prior experience in a cryptocurrency exchange is preferred.

• Deep, demonstrable expertise in clearing and settlement mechanics, collateral management, and the specific risk models (VaR, SPAN) used in futures, options, and swaps clearing.

• Expert understanding of CFTC regulations, Title VII of the Dodd-Frank Act, and the Principles for Financial Market Infrastructures (PFMI). Understanding of U.S. regulatory requirements with the New York State Department of Financial Services (NYDFS) BitLicense and Money Transmission License a plus.

• Proven ability to build, lead, and mentor a high-performing, independent Risk Management team.

• Exceptional written and verbal communication skills, with the ability to articulate complex quantitative concepts to the Board, regulators, and non-risk executives.

Bullish US LLC & CoinDesk Inc. are committed to offering competitive compensation and benefits. The anticipated base salary for this position is $265,000 - $330,000 + discretionary annual target bonus + performance incentives/benefits. Offered salary will be reflective of job related knowledge, skills and commensurate experience.

Bullish is proud to be an equal opportunity employer. We are fast evolving and striving towards being a globally-diverse community. With integrity at our core, our success is driven by a talented team of individuals and the different perspectives they are encouraged to bring to work every day.