Join the Future of Technology with ZILO™
At ZILO™, we’re redefining what’s possible in technology. ZILO™ is the UK-based FinTech specialising in global asset and wealth management software, designed to scale and transform businesses of all types using our own developed AI Technology.
Our mission is to digitalise the future of the global asset management industry. We are a team of experts with decades of combined experience at leading firms globally, who thrive in fast-paced environments and want to shape the future of technology. Every individual plays a key role in driving progress and making a real impact. We continuously strive to innovate and improve.
About the role:
This role owns compliance for ZILO’s registered transfer agent in the United States. It covers the Section 17A and 17Ad rule set and the registrant’s standing with the SEC, and it is the designated anti-money laundering officer, owning the Bank Secrecy Act programme, the customer identification programme and suspicious activity reporting. The holder sets the compliance standard for the US line, writes the positions the registrant relies on, and is the person the regulator deals with on how that standard is met.
The role carries both the regulatory compliance and the financial crime mandate for the US entity, and is expected to be direct about capacity, escalating where the workload or an independence requirement means a task should sit elsewhere.
Investor eligibility is enforced at the point of transaction through verifiable credentials that ZILO issues and maintains. The role owns the compliance position behind that: what each credential asserts, that those conditions reflect what the rules require, that eligibility is withdrawn when an investor’s status changes, and that the whole position is documented in a form that can be explained to a regulator and evidenced in practice.
Key Responsibilities:
Transfer Agent Registration and Standing
Own SEC transfer agent registration and the Form TA-1 and TA-2 cycle, including amendments as officers, control persons or activities change.
Own the written supervisory procedures for the registrant and keep them aligned to what the operation actually does.
Own SEC examination readiness: the record set, the walkthroughs, the control evidence and the narrative that explains a digital-native register to an examiner.
Own the annual study and evaluation of internal accounting control under Rule 17Ad-13, and ensure it reaches the technology layer rather than stopping at the operational one.
Own the custody and activity perimeter position – that ZILO holds no client money, fund units, tokens or private keys – and defend it in writing.
AML and Financial Crime
Act as the designated AML officer for the fund programme, owning policy, risk assessment, procedures, training and independent testing coordination.
Own suspicious activity report investigation, decision and filing with FinCEN.
Oversee the customer identification programme, ongoing due diligence, and sanctions and PEP screening for US investors.
Oversee transaction monitoring across the fiat and digital asset legs, and own the wallet freeze and unfreeze position where a financial crime trigger arises.
Rule Compliance and Control Ownership
Own compliance with the 17Ad rule set as it applies to turnaround, recordkeeping, the control book, aged record differences, safeguarding and instruction authentication.
Own the Regulation S-P position, including safeguarding of investor information and incident response and breach notification.
Own the conflicts of interest register, the financial crime prevention procedures covering fraud, bribery and tax evasion, and the whistleblowing channel.
Own the mapping of the conditions attaching to comparable no-action and exemptive relief in this product area, and track whether the model stays within them.
Second Line Oversight
Provide second line challenge to the operational processing delivered by the UK hub for the US line, including a…