About the Role
Kraken Adviser LLC’s Chief Compliance Officer is responsible for developing, implementing, administering, and enforcing the firm’s compliance program in accordance with Rule 206(4)-7 under the Investment Advisers Act of 1940 (the “Advisers Act”) and all other applicable federal and state securities laws and regulations. The CCO serves as the firm’s primary point of contact with the U.S. Securities and Exchange Commission, state securities regulators, and other regulatory bodies as applicable. The CCO must be a person of sufficient seniority and authority within the organization to compel adherence to the firm’s compliance policies and procedures. This role requires deep knowledge of the regulatory framework governing registered investment advisers, strong independent judgment, and the ability to balance regulatory obligations with business objectives. Experience working in a fintech, robo-adviser or a digital asset investment management firm is a plus.
The Opportunity
Compliance Program Design and Administration
- Design, implement, and maintain the firm’s written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and rules thereunder, as required by Rule 206(4)-7.
- Conduct at least an annual review of the adequacy of the firm’s compliance policies and procedures and the effectiveness of their implementation, and document the results of that review.
- Identify and assess regulatory risks across all business activities and develop controls to mitigate those risks.
- Maintain and update the firm’s compliance manual to reflect changes in applicable laws, regulations, SEC staff guidance, and business operations.
- Oversee the firm’s Code of Ethics, including pre-clearance and reporting of personal securities transactions, gifts and entertainment, outside business activities, and political contributions.
Regulatory Filings and Reporting
- Oversee the preparation, review, and timely filing of Form ADV Parts 1, 2A (Brochure), 2B (Brochure Supplements), and Form CRS, including annual amendments and interim updates.
- Ensure timely filings on any such applicable regulatory filings/ requirements (depending on the firm's business), including Form ADV, Form 13F, Form 13H, U4s, and U5s, required compliance training and oversight for testing and reporting under the Investment Advisers Act Rule 206(4)-7.
- Monitor and ensure compliance with state notice filing and investment adviser representative (IAR) registration requirements in all states where the firm operates.
SEC Examination Readiness and Regulatory Engagement
- Serve as the primary liaison with the SEC’s Division of Examinations (formerly OCIE) and state securities regulators during routine examinations, inquiries, and investigations.
- Maintain examination readiness at all times, including organized books and records, document retention systems, and staff preparedness.
- Coordinate responses to SEC deficiency letters, examination findings, and any enforcement inquiries.
Fiduciary Duty and Conflict of Interest Management
- Identify, disclose, and manage conflicts of interest arising from the firm’s business activities, compensation arrangements, affiliations, and investment practices.
- Oversee the firm’s best execution review process, including periodic analysis of execution quality for client transactions.
- Monitor the firm’s proxy voting policies and procedures and ensure votes are cast in the best interests of clients.
- Review and approve marketing materials, client communications, and performance advertising for compliance with the SEC’s Marketing Rule (Rule 206(4)-1).
Books and Records
- Ensure the firm maintains all books and records required under Rules 204-2 and 204A-1 of the Advisers Act, including client agreements, trade records, communications, and compliance documentation.
- Oversee the firm’s electronic communications surveillance and recordkeeping program, including email, messaging platforms, and other electronic channels.
- Implement and maintain a document retention and destruction policy consistent with regulatory requirements.
Investment Advisory Compliance
- Monitor adherence to client investment guidelines, restrictions, and suitability requirements.
- Oversee the firm’s trade allocation and aggregation policies to ensure fair and equitable treatment of all client accounts.
- Review and monitor the firm’s valuation policies and procedures for client portfolios, particularly with respect to illiquid or hard-to-value securities.
- Ensure compliance with custody requirements under Rule 206(4)-2 (the “Custody Rule”), including surprise examination and qualified custodian obligations.
Anti-Money Laundering and Financial Crime
- Oversee the firm’s anti-money laundering (AML) and know-your-customer (KYC) program, including customer identification, suspicious activity monitoring, and sanctions screening against OFAC lists.
- Coordinate with external counsel and compliance vendors on SAR filings and other FinCEN reporting obligations, as applicable.
Cybersecurity and Privacy
- Collaborate with IT and information security teams to ensure compliance with SEC cybersecurity guidance and Regulation S-P (Privacy of Consumer Financial Information).
- Oversee the firm’s incident response plan and ensure timely reporting of cybersecurity events to regulators and affected clients.
- Monitor vendor due diligence and third-party risk management as it relates to client data protection.
Training and Culture of Compliance
- Develop and deliver initial and ongoing compliance training for all employees, including investment professionals, operations staff, and senior management.
- Foster a culture of compliance throughout the organization, ensuring that employees understand their obligations and feel empowered to escalate concerns.
- Manage the firm’s compliance hotline or whistleblower reporting mechanism.
Regulatory Change Management
- Monitor proposed and final SEC rulemaking, no-action letters, risk alerts, and other regulatory developments that may affect the firm’s operations.
- Assess the impact of regulatory changes on the firm’s business and compliance program and implement necessary updates.
- Advise senior management and the board on emerging regulatory risks and industry trends.
Skills you should HODL
- Minimum of 5–10 years of progressive compliance, legal, or regulatory experience in the investment management industry, with a significant portion focused on SEC-registered investment adviser regulation.
- Deep working knowledge of the Investment Advisers Act of 1940, the Investment Company Act of 1940 (if applicable), SEC rules and regulations, and relevant state securities laws.
- Demonstrated experience designing, implementing, and administering compliance programs for SEC-registered investment advisers leveraging technology solutions.
- Experience managing SEC examinations and responding to regulatory inquiries.
- Strong understanding of fiduciary duty, conflicts of interest management, best execution, trade allocation, custody, and marketing compliance.
- Excellent written and verbal communication skills, with the ability to translate complex regulatory requirements into practical business guidance.
Nice to haves
- Bachelor’s degree required; Juris Doctor (JD) or other advanced degree.
- Prior fintech driven investment advisory experience.
- Experience with digital assets, cryptocurrency, or emerging financial products is a plus.
- Series 65 (Uniform Investment Adviser Law Examination) or Series 66 (Uniform Combined State Law Examination), or an equivalent qualifying designation recognized by NASAA (e.g., CFA, CFP, CAMS).
- Prior experience as a CCO, Deputy CCO, or senior compliance officer at an SEC-registered investment adviser.
- Familiarity with CFTC regulations, including Commodity Trading Adviser (CTA) and Commodity Pool Operator (CPO) requirements, is a plus.
- Experience with compliance technology platforms.
Unless a specific application deadline is stated in the job posting, applications are accepted on an ongoing basis. Please note, applicants are permitted to redact or remove information on their resume that identifies age, date of birth, or dates of attendance at or graduation from an educational institution. We consider qualified applicants with criminal histories for employment on our team, assessing candidates in a manner consistent with the requirements of the San Francisco Fair Chance Ordinance.
Kraken is powered by people from around the world and we celebrate all Krakenites for their diverse talents, backgrounds, contributions and unique perspectives. We hire strictly based on merit, meaning we seek out the candidates with the right abilities, knowledge, and skills considered the most suitable for the job. We encourage you to apply for roles where you don't fully meet the listed requirements, especially if you're passionate or knowledgable about crypto! We may ask candidates to complete job-related skills or work-style assessments as part of our hiring process. These assessments are designed to evaluate competencies relevant to the role and are applied consistently across candidates for similar positions. Assessment results are considered alongside other relevant information, such as experience and interviews, and are not the sole basis for any employment decision. As an equal opportunity employer, we don’t tolerate discrimination or harassment of any kind. Whether that’s based on race, ethnicity, age, gender identity, citizenship, religion, sexual orientation, disability, pregnancy, veteran status or any other protected characteristic as outlined by federal, state or local laws.