Our client is a purpose-built Layer 1 blockchain optimized for trading. The exchange represents the convergence of institutional-grade infrastructure with a fully regulated U.S. derivatives market. The CRO will join at the earliest stage and have an outsized impact on the exchange's design, regulatory posture, and long-term success. This is an opportunity to build a first-of-its-kind regulated digital asset exchange from the ground up.

Job Overview

The Chief Regulatory Officer is the first officer hire. This individual will own the regulatory relationship with the CFTC's Division of Market Oversight (DMO), serve as the primary compliance architect for the exchange, and drive the application from filing through designation. The CRO will work directly alongside outside counsel to produce a complete, pre-answered filing.

Key Responsibilities

DCM Application & Regulatory Strategy

• Own the end-to-end DCM application process alongside General Counsel, from pre-filing preparation through CFTC staff review, comment periods, and final designation
• Draft and assemble exhibits with outside counsel, ensuring the filing reads as a pre-answered staff interrogatory
• Serve as the primary point of contact with DMO staff, managing all written and oral communications throughout the review period
• Design the FCM/direct-access model, including customer onboarding, margin collection, and fund segregation under the applicable regulatory framework

Compliance Architecture

• Build the compliance program from the ground up: policies, procedures, staffing, technology, and governance
• Implement the market surveillance program, configuring alert parameters for manipulation, wash trading, spoofing, and disruptive trading practices
• Establish the AML/BSA program including KYC/CDD procedures, OFAC/sanctions screening, SAR/CTR filing, and Travel Rule compliance (FinCEN threshold + FATF Rec 16)
• Configure blockchain analytics tools for on-chain transaction monitoring specific to digital asset settlement
• Design and oversee the disciplinary program, including investigation protocols, hearing procedures, and sanction guidelines consistent with Core Principle 13
• Ensure audit trail completeness per CFTC Rule 38.550-553, including 5-year retention and reconstruction capability

Risk Management

• Define pre-trade risk controls: price collars, maximum order size limits, kill switches, self-trade prevention, and fat-finger protections integrated with the Monaco Protocol matching engine
• Set position limits and large trader reporting thresholds under Parts 15-21 and Core Principle 5
• Establish the margin framework for future products, coordinating with the DCO partner on initial margin, variation margin, and liquidation procedures
• Develop the financial integrity framework under Core Principle 11, including customer fund protection, settlement guarantee mechanisms, and default waterfall procedures
• Create and maintain the business continuity and disaster recovery (BC/DR) plan with documented annual testing

Governance & Board Relations

• Report directly to the Board of Directors and serve as a standing member of the Regulatory Oversight Committee (ROC)
• Prepare quarterly compliance reports for the Board, ROC, and NFA
• Advise the Board on regulatory developments, enforcement trends, and risk exposure
• Coordinate with the CPTO/CTO on technology-related compliance requirements (system safeguards, information security, capacity planning)
  
  About You

Required Qualifications

• 10+ years of compliance, risk management, or regulatory experience in CFTC-regulated markets
• Direct experience with DCM Core Principles, Part 38 regulations, and the DCM designation or application process
• Deep working knowledge of the DCM-DCO-FCM regulatory architecture, including clearing agreements, customer fund segregation, and intermediary obligations
• Prior experience managing relationships with the CFTC's Division of Market Oversight, Division of Enforcement, or Market Participants Division
• Demonstrated ability to build a compliance program from inception, including policy development, surveillance implementation, and staffing
• Experience with market surveillance platforms (NASDAQ SMARTS, Eventus Validus, or comparable)
• J.D. or equivalent legal qualification strongly preferred

Preferred Qualifications

• Former CFTC staff (DMO, DOE, or MPD) with direct knowledge of the application review process
• Previous CRO, CCO, or Head of Compliance title at a CFTC-registered DCM, SEF, or DCO
• Experience with digital asset derivatives, blockchain-based settlement, or crypto exchange operations
• Familiarity with NFA examination protocols, WinJammer reporting, and RSA management
• Existing relationships with current CFTC staff, and NFA leadership
• Experience guiding a DCM through the product self-certification process under Part 40

About Whistler Partners

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Interested?

This search is being led by Wolf Konstant (wolf@whistlerpartners.com) at Whistler Partners. Please contact them for a confidential conversation.