An established investment management firm seeks a Chief Compliance Officer (CCO) to lead and oversee the firm’s U.S. compliance function during its next phase of growth. Reporting directly to the President and working within a lean, collaborative team, this role will have end-to-end ownership of compliance across equities, fixed income, and futures, while supporting global client acquisition initiatives through robust regulatory, legal, and governance frameworks.
The firm is an SEC-registered investment adviser serving primarily Japanese retail and institutional investors and is actively expanding its fixed-income capabilities and U.S. business development efforts. The CCO will play a critical role in designing and implementing the compliance infrastructure required to support these strategic initiatives.
Key Responsibilities
Essential Duties and Responsibilities (95%)
- Administer the compliance program on an annual basis in accordance with the Investment Advisers Act of 1940, including identifying potential risks and implementing policy and procedural enhancements to mitigate those risks
- File Form ADV Parts I and II annually, as well as amendments for material changes throughout the year (Part III not applicable at this time)
- Update and maintain the compliance manual and related exhibits in accordance with applicable laws and regulations
- Oversee the Code of Ethics, including initial and annual holdings certifications, review of new account certifications, and approval of personal securities transactions
- Conduct the firmwide annual compliance risk assessment
- Preside over internal compliance meetings, participate in monthly global compliance meetings, and submit required compliance reports to the parent company
- Deliver quarterly firmwide compliance training and ad-hoc educational sessions on relevant regulatory and industry topics
- Oversee internal controls, including monitoring office access logs, gifts and entertainment logs, remote access reports, portfolio manager and trader certifications, and compliance attestations
- Conduct monthly electronic communications surveillance to identify potential insider trading or suspicious activity using Bloomberg monitoring tools and SharePoint systems
- Support and assist with the compliance portion of internal audits conducted by the parent company
- Collaborate with investment divisions on semi-annual broker evaluations, best execution reviews, and related activities
- Conduct and monitor Business Continuity Planning (BCP) exercises twice annually and ensure effectiveness during any BCP activation
- Draft and submit semi-annual certifications to the parent company confirming adherence to fund investment guidelines
- Distribute monthly certifications to portfolio managers and traders confirming compliance with investment guidelines
- Attend relevant compliance conferences, webinars, and industry events as appropriate
- Lead regulatory communications with the SEC, including managing onsite and remote examinations
- Establish and maintain compliant processes for Rule 206(4)-1 advertising reviews, multi-channel content oversight, and disclosure requirements
- Review and negotiate contracts, including investment management agreements (IMA), fee and expense provisions, termination clauses, and suitability language
- Provide governance oversight for cross-border data management and record-keeping
Other Duties and Responsibilities (5%)
- Communicate regularly with the President regarding significant or unusual matters
- Conduct scheduled trade checks in support of Tokyo headquarters
- Perform additional duties and responsibilities as assigned by the President
Qualifications
Required
- 10+ years of compliance experience at an SEC-registered investment adviser (prior CCO experience strongly preferred)
- Deep knowledge of SEC regulations, including the Investment Advisers Act and Rule 206(4)-7, with the ability to independently manage SEC examinations and regulatory interactions
- Native-level English proficiency (written and verbal)
- Demonstrated compliance judgment and supervisory leadership
- Strong drafting and writing skills for policies, Form ADV, and regulatory reporting
- High integrity, independence, and ability to operate autonomously
- Business-oriented, solution-focused mindset with a practical approach to regulatory challenges
Preferred
- Experience with Aladdin or comparable OMS/monitoring systems
- Bilingual English/Japanese capability and/or experience working in Japanese or cross-cultural organizational environments
