Manager, Internal Audit

Reports to:

Position Overview

Bullish’s Internal Audit team provides independent, risk-based assurance across the organisation’s financial, operational, and technology control environments. As Bullish continues to grow its global regulated exchange and digital asset businesses, the Internal Audit function plays a central role in providing independent and objective assurance on internal controls, effectiveness of risk management and corporate governance.The Manager, Internal Audit will be a key member of this team, based in our New York office and reporting directly to the Group Head of Internal Audit.

The primary focus of this role is planning and executing SOX compliance testing across Bullish’s US operations, as well as broader involvement in the annual internal audit program.

Role & Responsibilities

• Lead and execute end-to-end SOX internal control testing (Entity level controls, business process controls, and IT controls), including scoping, walkthroughs, test of design, and test of operating effectiveness.

• Manage preparation of workpapers, control narratives, and audit findings documentation in accordance with Internal Audit methodology and professional standards.

• Identify control deficiencies, assess their significance, and track remediation with process owners through to closure.

• Liaise with external auditors (Big 4) to co-ordinate reliance testing and provide timely support for the annual financial statement audit.

• Assist in developing and maintaining the SOX risk and control matrix (RCM), ensuring it remains current as the business evolves.

• Contribute to the annual Internal Audit risk assessment and planning process.

• Prepare clear, concise internal audit reports and executive-level summaries for senior management and the Audit Committee.

• Stay current with regulatory developments relevant to Bullish’s US operations, including SEC, CFTC, and NYSE/BLSH listing requirements.

Experience & Qualifications

• 5+ years of progressive internal or external audit experience, with a strong focus on SOX compliance and financial controls testing.

• Experience in financial services, fintech, digital assets, or another regulated industry strongly preferred.

• Professional qualification: CPA, CIA, or equivalent (CA, ACCA) are strongly preferred; CISA is a plus.

• Solid understanding of COSO framework, PCAOB standards, IFRS, and US GAAP.

• Demonstrated ability to manage audit engagements independently and communicate findings clearly to varied audiences, including senior management.

• Familiarity with business cloud platforms (e.g., Workday) and audit management and GRC platforms (e.g., Floqast).

• Excellent written and verbal communication skills; high attention to detail and strong project management ability.

• Exposure to LLM-based tools and AI-assisted processes, and interest in how these intersect with audit and risk.

• Self-starter comfortable getting hands-on with building agentic AI solutions using LLM tools to enhance audit processes (e.g., automating control testing, evidence gathering, or RCM maintenance).

• Familiarity with cryptocurrency, blockchain technology, or digital asset markets is a plus.

Bullish US LLC & CoinDesk Inc. are committed to offering competitive compensation and benefits. The anticipated base salary for this position is $130,000 - $160,000 + 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.