Compliance Officer

Role Purpose

• The Compliance Officer is responsible for establishing, administering and maintaining BloFin’s compliance management system (“CMS”), so that BloFin complies at all times with its VARA licence conditions, the VARA Regulations, Rules and Directives, the Federal AML-CFT Laws and all other applicable UAE laws, the applicable laws of any other jurisdiction in which BloFin carries out VA Activities or similar business, and its own constitutional documents and internal policies.
• The CO is accountable for identifying and escalating material non-compliance, notifying VARA and other relevant authorities where required, and embedding a professional compliance culture across the Board, Senior Management and Staff.

Regulatory Alignment

VARA requires every VASP to appoint a Compliance Officer who possesses at least five (5) years of relevant experience in a compliance function, is a Fit and Proper Person as approved by VARA, is resident in the UAE or holds a UAE passport, is a full-time employee of the VASP and reports directly to the Board. The appointment must be reviewed annually to confirm the CO remains Fit and Proper. The CO is ultimately responsible for establishing and administering the CMS and for notifying VARA and other relevant authorities of any material non-compliance by the VASP, its Board or its Staff. Compliance activities may be delegated to appropriate professionals, provided the CO remains accountable and VARA’s outsourcing requirements are met. As head of the compliance function, the CO is treated as a member of Senior Management and may not hold a position on the Board.

Reporting Line

The CO reports directly to the Board of Directors and attends the Compliance Committee where one is established. The CMS must be independent of all operational and business functions, and the compliance function must be segregated from and independent of the operational and related supervisory functions. The CO may liaise with the CEO on administrative matters only; this does not create a reporting line and does not restrict the CO’s direct and unrestricted access to the Board. The CO works alongside the MLRO, the Head of Risk, the CISO / DPO, the Responsible Individuals, the Company Secretary and the internal and external auditors.

Key Responsibilities of the Role Compliance Management System

• Establish, administer and maintain an effective CMS that covers all relevant aspects of BloFin’s operations, including unfettered access by the Board and relevant Staff to necessary records and documentation.
• Ensure the CMS is independent of all operational and business functions, and that the CO is notified promptly of any material non-compliance.
• Ensure the compliance function has the technical competence, financial and non-financial resources and experience necessary to perform its functions.
• Design and run a risk-based compliance testing and monitoring programme that regularly selects and reviews different areas of the business and analyses key performance and risk indicators, to identify potential compliance violations.
• Review and update the CMS and compliance policies and procedures from time to time so they remain aligned with BloFin’s business and the changing regulatory landscape.

Compliance Policies and Procedures

• Develop and implement clear and detailed compliance policies and procedures that enable all Staff and the Board to comply with all applicable legal and regulatory requirements, including licence conditions, record keeping, business practices, AML/CFT, and client, proprietary and Staff dealing requirements.
• Ensure the policies provide for client complaints to be handled properly, with appropriate remedial action, and investigated by Staff who are not directly involved in the subject matter of the complaint.
• Develop and implement compliance policies and procedures, including the Business Continuity and Disaster Recovery Plan (“BCDR Plan”) required under the Technology and Information Rulebook, working with the CISO, COO and Head of Risk.

Regulatory Notifications and VARA Engagement

• Notify VARA and other relevant authorities of any material non-compliance by BloFin, its Board or its Staff with applicable legal and regulatory requirements.
• Ensure a report is submitted to VARA immediately upon discovery of any violation or breach of any law, Regulation, Rule or Directive related to the conduct of any VA Activity.
• Ensure VARA is notified in writing of any changes to the items in BloFin’s annual regulatory submission, and immediately of any criminal or material civil action, Insolvency Proceeding, investigation, inspection or enquiry against BloFin, its Board members, UBOs or Senior Management.
• Coordinate with the CISO so that material cybersecurity events, and events triggering the BCDR Plan that materially impact operations, are reported to VARA within seventy-two (72) hours of detection.
• Ensure information on BloFin’s activities in jurisdictions other than the Emirate is disclosed to VARA on request.
• Act as a primary point of contact for VARA on compliance matters, dealing with VARA in an open and transparent manner, and coordinate timely, accurate responses to VARA requests, RFIs, supervisory queries and inspections.

Regulatory Reporting

• Coordinate and oversee the completeness and timeliness of BloFin’s monthly, quarterly and annual regulatory submissions to VARA, working with the CFO, Head of Risk and Company Secretary.
• Ensure quarterly submissions include the minutes of all Board and Board committee meetings, the statement of compliance with financial requirements, financial projections and strategic business plans, and the Head of Risk’s risk exposure report.
• Coordinate the annual assessment by Senior Management of BloFin’s compliance with applicable laws, Regulations, Rules and Directives for the fiscal year.

Training and Compliance Culture

• Ensure Staff, including Senior Management, are properly and adequately trained in their understanding of and compliance with all applicable laws and regulatory requirements, including those relating to consumer protection and AML/CFT.
• Ensure operational policies and procedures are communicated to new hires within their first thirty (30) calendar days, and that updated policies are promptly communicated and made available to all Staff.
• Ensure all Staff performing compliance functions are Fit and Proper Persons and possess the necessary skills, qualifications and experience for their roles.

Compliance Risk, Board Reporting and Corrective Action

• Assess emerging compliance issues and risks, and provide input to the Head of Risk on compliance-function and regulatory risks for the quarterly risk exposure report.
• Report compliance activities and compliance audits to the Board.
• Where necessary, ensure appropriate corrective actions are taken in response to deficiencies in the CMS or non-compliance with any applicable laws or regulatory requirements, and track them to closure.

AML/CFT Coordination with the MLRO

• Act as BloFin’s internal counterpart to the MLRO, ensuring the MLRO has timely access to the information, systems and Staff needed to discharge the MLRO’s duties.
• Receive immediate notification from the MLRO when a Suspicious Transaction report has been made, provided this does not constitute tipping-off.
• Monitor that the MLRO arrangement continues to meet the management requirements of the Company Rulebook, and elevate any concerns to the Board.

Anti-Bribery and Corruption

• Hold primary and day-to-day responsibility for implementing BloFin’s anti-bribery and corruption policy and monitoring its effectiveness, addressing any deficiencies as soon as possible.
• Receive reports from the Board or Staff of actual, suspected or solicited breaches; prepare a written summary of any oral report; and investigate each report by appointing an independent Entity to commission the investigation.
• Handle all reports, including those from outside BloFin, confidentially, protecting the identity of the person reporting in accordance with applicable UAE law.
• Advise the Board of the existence of any investigation and of any finding of unlawful conduct, and ensure any such finding is reported to VARA immediately.
• Retain investigation reports and remediation summaries for no less than eight (8) years from completion of the remedial action, and make them available to VARA on request.

Delegation, Conflicts and Records

• Where compliance activities are delegated to appropriate professionals, remain accountable for the implementation of the CMS and ensure all applicable Company Rulebook requirements, including outsourcing management requirements, are met.
• Administer BloFin’s conflicts of interest policy and the conflicts of interest register, and BloFin’s personal dealing procedures, including prior written approval of Board and Staff dealings in Virtual Assets and six-monthly position notifications.
• Ensure compliance records are retained for no less than eight (8) years, or indefinitely where records may relate to the national security of the UAE.

Requirements for the Role Mandatory Regulatory Requirements

• Minimum five (5) years of relevant experience in a compliance function.
• A Fit and Proper Person as approved by VARA, with the appointment reviewed annually; VARA may request evidence that these requirements continue to be met.
• Resident in the UAE or a UAE passport holder.
• Reports directly to the Board.
• May not hold a position on BloFin’s Board, and may not act as the CISO.
• May hold a board position in another Entity only with the prior written approval of the Board after conflicts screening, and may not hold an employee position in any other Entity without the Board’s prior written consent.
• May hold other non-client-facing roles within BloFin only where these do not create conflicting duties, and subject to VARA’s Fit and Proper assessment.

Required Qualifications

• Bachelor’s degree in Law, Finance, Economics, Business, Accounting or a related field.
• Professional compliance qualification preferred, such as an ICA Diploma or Advanced Certificate in Compliance or Financial Crime, CAMS, or equivalent.
• Strong working knowledge of the VARA Regulations and Rulebooks, the Federal AML-CFT Laws, FATF standards on virtual assets and VASPs, and UAE data protection requirements.

Required Experience

• At least five (5) years of relevant compliance experience (VARA minimum); seven (7) or more years in a regulated financial services, fintech, exchange, brokerage, banking or VASP environment preferred.
• Experience designing and running a compliance management system, compliance monitoring and testing programmes, and Board-level compliance reporting.
• Experience engaging directly with regulators, including regulatory notifications, RFIs, inspections and licence applications.
• Experience at a virtual asset exchange or trading venue, including client onboarding, market conduct and custody arrangements, strongly preferred.

Key Skills and Competencies

• Independence and the ability to challenge Senior Management and elevate issues to the Board without restriction.
• Sound regulatory interpretation and judgment across VARA, AML/CFT, market conduct and consumer protection requirements.
• Strong investigation, documentation and Board-reporting skills.
• Ability to work effectively with MLRO, the Head of Risk, the CISO / DPO, operations, technology and external advisers.
• High integrity, confidentiality and Fit and Proper suitability.

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