Director of Compliance

Exchange & Clearinghouse Compliance Operations

• Own day-to-day compliance monitoring and program execution across EXI’s DCM and DCO regulatory obligations under CFTC Parts 38 and 39.
• Maintain and administer EXI’s compliance procedures, policies, and internal controls frameworks, including the Compliance Manual and Compliance Desk Manual.
• Track and manage EXI’s regulatory calendar, including filing deadlines, self-certification obligations under Part 40, and periodic reporting requirements.
• Assist in the preparation and review of annual compliance reports, Core Principle assessments, and other periodic regulatory deliverables.
• Support the CRO/CCO in managing all aspects of CFTC examinations, including document production, coordinating responses, and scheduling with Division staff.

Trade Surveillance

• Manage EXI’s trade surveillance program, including oversight of the Eventus/Validus platform configuration, alert review workflows, and investigation procedures.
• Mentor the Compliance team, helping set performance expectations and developing their capacity to operate independently.
• Review and disposition surveillance alerts across EXI’s automated detection scenarios, including layering, spoofing, wash trading, and other manipulative or disruptive trading practices.
• Oversee the escalation, documentation, and resolution of surveillance investigations, including maintaining investigation files to regulatory standards.
• Evaluate and enhance detection logic, scenario coverage, and alert thresholds in coordination with Eventus and outside counsel.
• Ensure the surveillance program satisfies applicable DCM Core Principles (Core Principle 2) and applicable CFTC regulations.

CFTC Regulatory Inquiries & Correspondence

• Serve as the primary internal point of contact for inbound inquiries from CFTC Divisions (DMO, DCR, MPD, DOD), coordinating internally and with the Legal department.
• Draft initial responses to CFTC inquiries, information requests, and examination questions, with review by the CRO/CCO and/or Legal prior to submission.
• Assist in maintaining the Jira log of all regulatory correspondence and open items, ensuring timely resolution and appropriate recordkeeping under CFTC Rule 1.31.
• Assist in the preparation of responses to no-action requests, rule interpretations, and other matters requiring CFTC engagement.

Cross-Functional Liaison -- Operations & Engineering

• Act as the primary compliance liaison to the Operations and Engineering teams, ensuring regulatory requirements are understood and incorporated into system design, product development, and operational workflows.
• Collaborate with Engineering on compliance-related system requirements, including trade surveillance data feeds, regulatory reporting, kill switch functionality, drop copy services, FIX protocol configurations, and recordkeeping infrastructure.
• Partner with Operations on participant onboarding (AML/CIP/KYC), user authorization workflows, and operational compliance matters.
• Participate in cross-functional reviews of new product initiatives, rule changes, and system modifications to identify and address compliance implications.
• Advise Engineering on regulatory reporting requirements related to Part 16 and 17 obligations.
• Contribute a regulatory compliance perspective to incident response and operational exception processes.

Additional Responsibilities

• Assist the CRO/CCO with regulatory strategy, petition preparation, and engagement with CFTC staff on EXI’s business initiatives.
• Maintain awareness of evolving CFTC rules, guidance, no-action letters, and enforcement actions relevant to EXI’s business.
• Contribute to the development and delivery of compliance training for EXI staff.

Requirements

• 8–12 years of compliance, regulatory, or legal experience at or with CFTC- or SEC-regulated entities or SROs, including DCMs, DCOs, FCMs, broker-dealers, exchanges, clearinghouses, or similar regulated markets or registrants.
• Substantive knowledge of CFTC regulations, including Parts 1, 16, 17, 38, 39, and 40 and familiarity with Core Principle obligations for exchanges and clearinghouses.
• Demonstrated experience with CFTC regulatory reporting, specifically Parts 16 and 17; comparable SEC or FINRA reporting experience is considered highly transferable.
• Experience in trade surveillance, including alert review, investigation management, and surveillance platform administration.
• Demonstrated experience drafting regulatory correspondence, responding to examinations, or managing relationships with government regulators or SROs.
• Strong writing and analytical skills, with the ability to synthesize complex regulatory issues into clear, actionable internal and external communications.
• Experience supervising or mentoring junior compliance or surveillance staff.
• Ability to work cross-functionally with technical teams (Engineering, Operations) and translate regulatory requirements into operational specifications.
• Bachelor’s degree or equivalent experience required.

Preferred Qualifications

• Direct experience at a DCM or DCO, or within the energy or electricity derivatives markets.
• Familiarity with automated surveillance platforms (e.g., Eventus/Validus, Nasdaq Surveillance, or similar tools).
• Experience with CFTC examination processes.
• Working knowledge of FIX protocol, trading system architecture, or financial technology infrastructure.
• J.D. or advanced degree in a relevant discipline.