• Monitor and investigate AML alerts generated across multiple program partners. • Monitor and investigate alerts related to negative news, OFAC and PEP screening, and license violations • Conduct due diligence and ongoing monitoring of cannabis clients • Prepare partner marijuana specific SAR reports in accordance with FinCEN’s guidance in distinguishing limited filings, priority filings, and termination filings • Support the development and calibration of transaction monitoring rules tailored to specific typologies • Administer the end-to-end CRB onboarding and ongoing monitoring, including cannabis specific reviews, license verifications, and beneficial ownership analysis • Conduct regular CRB account reviews – validating cash deposits, sales activity, and transaction patterns consistent with licensed operations • Support partner bank regulatory examinations and internal/external audits; prepare materials and respond to examiner inquiries

• Leads and develops a team of professionals providing oversight, expert regulatory guidance to specialized domains of TD's KYC programs • Oversees timely execution of client due diligence reviews using a risk-based approach • Manages a team to perform job functions in line with policies, standards, and procedures • Works with senior management on highly complex, confidential, or high visibility projects • Ensures an integrated approach with other business management areas

• Lead, coach, and develop a team of AML analysts by providing regular feedback, tailored coaching, and early performance support. • Oversee the review of systematic alerts triggered by suspicious activity, ensuring every investigation is thorough, well-reasoned, and clearly documented from first review through to closure or escalation. • Perform independent quality reviews of completed TM investigation decisions before closure or escalation. • Proactively identify issues and inefficiencies in processes and drive solutions through a mix of partnerships, technology, process, and procedure changes. • Track and report on key team metrics, including SLA adherence, QA pass rates, and false-positive trends, using these insights to guide coaching and process improvements. • Partner with compliance on complex or high-risk cases and represent the team's findings clearly when escalating to senior stakeholders. • Keep up to date with evolving AML typologies and regulatory expectations relevant to LemFi's markets. • Flag control weaknesses, high-risk cases, or tooling/process issues to leadership promptly and clearly, following agreed protocols.

Role Description We’re hiring our first Head of Financial Crimes Compliance (FCC) to architect, operationalize, and lead our compliance strategy across BSA/AML, sanctions, licensing, and financial crime-related risk. Reporting to the General Counsel, this is a senior role for a seasoned leader who can roll up their sleeves and design the program, set policy, manage regulatory engagement, and build processes and tooling while we scale. This role will also serve as the firm’s board-appointed BSA Officer, with full accountability for compliance with the Bank Secrecy Act and related regulatory obligations. The role will also dual-hat as the firm’s OFAC Sanctions Compliance Officer, responsible for administering the firm’s Sanctions Compliance Program. Where fraud serves as a predicate offense for FCC-related risks, the Head of FCC will also be responsible for factoring in fraud and payments-related risk into the broader FCC control framework. Program Ownership and Strategy - Design, implement, and continuously improve a risk-based BSA/AML and Sanctions Compliance Program (policies, standards, procedures, governance, testing, training). - Maintain an FCC program implementation plan to support timely program enablement. - Conduct the annual FCC-risk assessment covering BSA/AML and Sanctions. - Serve as the firm’s board-appointed BSA and Sanctions Compliance Officer, responsible for program oversight, reporting, and annual filings/certifications. - Establish FCC risk appetite standards and metrics in alignment with enterprise risk management (ERM) standards and board oversight. - Define FCC KRIs and KPIs and reporting cadence for executive leadership and the Board. - Partner with Product, Engineering, and Operations teams on FCC-related tooling requirements to support process excellence. Governance and Reporting - Chair internal compliance committee; deliver board-level reporting on program health, key risks, issues, testing results, and remediation status. - Coordinate with Legal, Risk, InfoSec, and Finance on cross-functional matters impacting FCC-related risks. Financial Crime Prevention - Own KYC/KYB, CDD/EDD, transaction monitoring, case management, SAR/STR processes, OFAC screening, list management, and reporting requirements. - Stand up cross-border controls (jurisdictional risk mapping, licensure checks, VASP/PSP counterparty risk, and Travel Rule requirements as applicable). Regulatory and Financial Partner Engagement, Program Management, and Reporting - Serve as the primary contact for regulators, auditors, and bank partners on FCC-related matters. - Coordinate exams, audits, independent testing, compliance monitoring and testing, and model validation related to the FCC program. - Lead regulatory remediation and corrective action plans (CAPs) for FCC-related matters, tracking commitments and outcomes to closure and providing periodic reporting to senior management and the Board. Partnerships and Licensing - Structure and manage bank and non-bank financial institution FCC-related controls and partnerships, including program governance, adherence to SLAs, reporting, FCC-related support for bank/financial partner periodic review and onboarding, and change management. - Support licensing strategy, including MSB registration, MTL roadmap, evaluation and management of FX/crypto-specific requirements and passporting implications, in partnership with Legal, Ops, and outside counsel. Operations and Process Enablement - Build and mentor a lean compliance team responsible for day-to-day program execution. - Select and administer vendor ecosystem (KYB/KYC/IDV, sanctions screening, blockchain analytics, transaction monitoring, case management, AI process optimization) to support effective and scalable program execution (with a bias for process automation and operational efficiency over headcount). - Embed compliance-by-design across product, engineering, and go-to-market; run impact assessments for new features and geographies. Qualifications - 8–10 years of progressive experience in BSA/AML and sanctions compliance, with in-house leadership at a payments and/or crypto company (or equivalent). - Demonstrated expertise in cross-border payments (e.g., corridors, fiat/crypto touchpoints, correspondent banking, remittance). - Proven track record in regulatory remediation and/or greenfield program development (policies, controls, governance, testing). - Experience managing bank/financial partner relationships (program oversight, reporting, exams, reporting, periodic reviews). - Deep knowledge of applicable U.S. and international requirements (e.g., BSA, OFAC, FATF, travel rule regimes, licensing frameworks). - Hands-on building experience, ability to set strategy and execute, and to thrive in a high-speed, start-up environment. Preferred - Exposure to blockchain analytics tools (e.g., Chainalysis, TRM, Elliptic) and payment (fraud) risk platforms. - Experience with MSB/MTL licensing, e-money regulations, PSPs, VASP frameworks, and cross-jurisdictional compliance. - Experience with FCC model risk governance (alerting thresholds, segmentation, tuning, back-testing) and data quality controls. - Prior board and regulatory reporting experience and comfort with external counsel coordination. - Enterprise Risk Management (ERM) experience (risk taxonomy, RCSA, issue management, KRI design). Compensation The base salary range for this role is $200,000 – $250,000, commensurate with experience. Benefits - Health and well-being: comprehensive medical, dental, vision, and life insurance with generous company contribution. - Financial future: meaningful equity in an early-stage, high-growth company, and a 401(k) for retirement savings. - Time and flexibility: unlimited PTO, 10 federal holidays, and a flexible working model so you can do your best work from wherever you thrive.