Join the World's Top Legal Talent Network

Head of Compliance for Energy and Commodities Business and Chief Compliance Officer FCM

Role Summary The person will run compliance for the firm’s Energy and Commodities Brokerage business and its related Introducing Brokers (“IBs”) which predominantly execute Block transactions. In addition, serve as the Chief Compliance Officer for the firm’s FCM. The ideal candidate will bring at least 10 years of relevant experience and a deep understanding of the Energy and Commodities Business and the Compliance requirements of an FCM. This role is highly cross-functional and will partner with Legal, Risk, Operations, Technology, Front Office, and Internal Audit to sustain a robust, well-documented, and tested compliance management system across the SD and SBSD entities.

Key Responsibilities The Compliance Officer will support and enhance the design, execution, monitoring, and continuous improvement of the firm’s FCM and IB compliance programs. Core responsibilities include:

• Governance and Program Management. Maintain and enhance the compliance program consistent with Commodity Exchange Act and CFTC requirements for FCMS and Introducing Brokers. Support the CCO in developing the annual compliance plan, maintaining policies and procedures, and overseeing governance forums, charters, and issue management routines. Coordinate program documentation, regulatory mapping, interpretations, and implementation of new and amended rules. Facilitate compliance training across first and second lines.
• CCO Reporting and Board/Senior Management Engagement. Preparing the CFTC Annual report for the FCM, including testing results, exceptions, and remediation tracking. Coordinate management certifications, board presentations, and attestations, ensuring timely escalation and governance of material compliance matters.
• Risk Management and Surveillance. Partner with the Risk function to maintain the FCM risk management program, including independent testing, model/limit governance, and periodic reviews. For the FCM and IBs enhance trade surveillance, communications surveillance, and fair dealing controls, including calibration and documentation of alerts and escalations.
• Testing, Monitoring, and Issue Management. Design and execute risk-based compliance testing and ongoing monitoring for FCM and IB requirements, including trade reporting, business conduct, daily trading records, recordkeeping, and sales/trading practices. Track findings, corrective actions, and target dates; validate remediation; maintain control inventories and RCSAs in coordination with Operational Risk and Internal Audit.
• Regulatory Exams, Inquiries, and Policy Change. Serve as a point of contact for FCM and IBs regulatory examinations and inquiries by the CFTC and NFA, and, as applicable, other SROs. Support timely, accurate responses; coordinate data and document productions; and maintain exam workpapers, responses, and remediation evidence. Monitor regulatory developments, industry guidance, and enforcement actions; drive impact assessments, gap analyses, and implementation workstreams.
• Books and Records and Record Retention. Oversee compliance with applicable books-and-records requirements, including daily trading records, voice and electronic communications retention, supervisory review, and accessibility/indices requirements. Coordinate system-of-record documentation, data lineage, and change management across reporting and surveillance platforms.
• Culture, Training, and Advisory. Provide proactive advisory support to Front Office, Operations, and Technology on FCM/IB rules, including cross-border and U.S. person analyses, ANE considerations, substituted compliance, and applicability determinations. Develop and deliver targeted training addressing regulatory changes, control enhancements, and exam themes.

Qualifications

• Bachelor’s degree required; advanced degree or recognized compliance credential (e.g., CRCM, FRM, CFA, CAIA, ACAMS) a plus.
• Minimum of 10 years of compliance, legal, risk, or audit experience focused on derivatives or securities compliance at an SD, SBSD, broker-dealer, FCM, bank, or comparable institution.
• Demonstrated experience with governance and annual CCO reporting processes, compliance testing and monitoring, and management of regulatory exams.
• Strong understanding of business conduct standards, disclosures, suitability, fair dealing, and daily trading recordkeeping.
• Experience with risk management program requirements, trade and communications surveillance, and escalation frameworks.
• Proficiency with data analysis and control documentation; experience with reporting/surveillance tools, data warehouses, and issue tracking systems preferred.
• Excellent written and verbal communication skills, with an ability to explain complex regulations to diverse stakeholders and produce clear governance documentation.
• High integrity, sound judgment, and a strong ownership mindset with the ability to operate in a fast-paced, control-focused environment.

Key Competencies

• Regulatory acumen and practical judgment applying CFTC and NFA rules to complex trading and operational scenarios.
• Structured problem-solving and root-cause analysis with a focus on durable remediation.
• Risk-based thinking and prioritization; strong project management and organization.
• Collaborative approach with the confidence to challenge, escalate, and influence across all levels.
• Detail orientation with the ability to synthesize and communicate material risks to senior management.

Additional Information

• Travel requirement: Occasional, including for regulatory exams and on-site reviews.