ABOUT KIRK ELLIOTT PRECIOUS METALS
Kirk Elliott Precious Metals (KEPM) is a highly successful precious metals dealer and the legacy operating business of Discern Global. The company has built an incredibly strong reputation grounded in the highest professional and ethical standards, transparency, and an exceptional client experience, supported by a loyal client base and a team of high performers.
Building on this strong foundation, there is a significant opportunity ahead to keep growing and elevating the business. As KEPM continues to scale, the creation of a dedicated in-house compliance function is an important part of that next chapter, ensuring the company's operations remain sound, regulatory obligations are met with rigor, and the foundation is built for continued growth.
POSITION SUMMARY
The Compliance Manager is a newly created, high-ownership role responsible for building, managing, and continuously improving KEPM's compliance program. Reporting directly to the CEO, this person serves as KEPM's dedicated compliance professional and primary owner of all BSA, AML, OFAC, FinCEN, and other federal and state regulatory reporting obligations applicable to a precious metals dealer and money services business.
This is not a support role inside a larger compliance department. The Compliance Manager will work independently and with a high degree of ownership, partnering closely with the General Counsel and senior leadership to keep the company compliance audit-ready, operationally sound, and fully aligned with applicable federal and state regulations. The ideal candidate is a self-directed, detail-oriented compliance professional who thrives in an environment where they are responsible for both the strategy and the execution.
A central part of this role is ensuring that KEPM's compliance program reflects the company's deep commitment to ethical standards and doing right by its clients. This calls for someone who understands that compliance is not simply a regulatory obligation but a direct expression of the integrity that defines how KEPM operates.
KEY RESPONSIBILITIES
- Serve as KEPM’s Compliance Officer: Responsible for developing and implementing the company’s overall compliance program.
- BSA/AML Program Ownership: Build, maintain, and continuously improve KEPM's Bank Secrecy Act and Anti-Money Laundering program, including policies, procedures, risk assessments, internal controls, and the overall program framework.
- Transaction Monitoring and SAR Filing: Conduct ongoing transaction monitoring, investigate potentially suspicious activity, and prepare and file Suspicious Activity Reports with FinCEN on a timely, accurate, and defensible basis.
- OFAC and Sanctions Compliance: Administer OFAC screening processes and ensure all customer relationships and transactions are consistent with current U.S. sanctions programs.
- Form 8300 and Cash Reporting: Manage IRS Form 8300 reporting obligations for cash transactions, including identification of reportable transactions, accurate and timely filing, and recordkeeping in accordance with regulatory requirements.
- KYC, CDD, and EDD: Oversee customer due diligence and enhanced due diligence processes, including CIP, beneficial ownership compliance under the CDD Rule, and ongoing monitoring and periodic review of high-risk customer relationships.
- Multi-State Dealer Licensing: Track, manage, and renew KEPM's precious metals dealer registrations and licenses across applicable states, coordinating with the General Counsel and outside counsel as needed.
- IRA Custodian and Depository Relationships: Serve as the compliance point of contact for KEPM's IRA custodian and depository relationships, supporting due diligence reviews, onboarding requirements, and ongoing compliance oversight of those partnerships.
- Regulatory Examination Readiness: Maintain documentation, records, and internal controls in a state of continuous exam readiness and coordinate KEPM's response to regulatory inquiries, audits, and examinations.
- Compliance Training: Develop and deliver compliance training for KEPM staff on BSA/AML obligations, red flags, OFAC requirements, and other regulatory responsibilities specific to the precious metals industry.
- Cross-Functional Partnership: Partner closely with the General Counsel, senior leadership, and operational teams to ensure compliance considerations are built into business decisions, new products, and client-facing processes from the start.
CHARACTER AND CULTURE FIT
- Beyond technical expertise, the right person fits how KEPM operates and leads. We are looking for a compliance professional who brings:
- Uncompromising Integrity: Operates with the highest ethical standards in every interaction, treating compliance not as a checkbox but as a direct expression of the company's values and commitment to doing right by its clients.
- Ownership Mindset: Approaches the role with accountability and initiative, building and improving rather than simply maintaining, and takes full responsibility for the quality and completeness of the compliance program.
- Proactive and Self-Directed: Identifies regulatory risks and gaps before they become problems, and brings solutions and recommendations to leadership without waiting to be asked.
- Collaborative and Service-Minded: Understands that compliance exists to protect the business and the people it serves, communicates clearly with colleagues across departments, and makes it easier, not harder, to do the right thing.
- Detail-Oriented and Thorough: Brings precision and care to every regulatory filing, risk assessment, and written communication, knowing that accuracy and completeness are non-negotiable in this work.
QUALIFICATIONS
- BSA/AML Experience: Five or more years of hands-on BSA/AML compliance experience with direct ownership of SAR filing, transaction monitoring, risk assessments, and program management. Experience inside a non-bank financial institution, money services business, fintech, or similar regulated environment is strongly preferred.
- FinCEN and MSB Knowledge: Working knowledge of FinCEN regulations applicable to money services businesses and precious metals dealers, including Form 8300 cash reporting obligations, MSB registration requirements, and FinCEN 314(a) and 314(b) processes.
- OFAC and Sanctions: Demonstrated experience administering OFAC screening programs and managing sanctions compliance obligations.
- KYC and Customer Due Diligence: Solid foundation in CIP, CDD, EDD, and beneficial ownership compliance, including experience managing high-risk customer reviews.
- Independent Operator: Proven ability to work as a solo compliance professional or primary compliance owner, exercising sound judgment and managing a full program with limited supervision.
- CAMS Certification: CAMS (Certified Anti-Money Laundering Specialist) certification is strongly preferred.
- Precious Metals or Physical Asset Experience: Direct experience in the precious metals, bullion, commodities, or physical asset industry is a plus and will be given strong preference where present.
- IRA Custodian or Trust Experience: Familiarity with IRA custodian compliance obligations, self-directed IRA transactions, or trust company operations is a meaningful advantage.
- Multi-State Licensing: Experience managing state-level dealer, transmitter, or financial services licensing obligations across multiple jurisdictions is a plus.
- Education: Bachelor's degree required. CAMS or other relevant compliance certifications are valued.
Pay: From $70,000.00 per year
Benefits:
- 401(k)
- Dental insurance
- Employee assistance program
- Health insurance
- Life insurance
- Paid time off
- Parental leave
- Retirement plan
- Vision insurance
Experience:
- hands-on BSA/AML compliance: 5 years (Required)
License/Certification:
- CAMS (Certified Anti-Money Laundering Specialist) (Preferred)
Work Location: Remote
