Role Overview The High Risk ODD Analyst is responsible for conducting continuous monitoring and periodic reviews of high-risk retail customers, transactions, and entities within a cryptocurrency or digital assets environment. The role ensures ongoing compliance with AML/CFT regulations and internal policies by performing risk-based ongoing due diligence on retail accounts with elevated risk profiles, detecting emerging risks, and ensuring timely remediation actions. Key Responsibilities Ongoing Monitoring & Periodic Reviews
Conduct periodic High Risk ODD reviews on existing high-risk retail customers, including PEPs, sanctioned individuals/entities, and customers in high-risk jurisdictions Perform continuous transaction monitoring and behavioral analysis to identify changes in risk profile or suspicious activity patterns Review and analyze crypto transactions, wallet activities, and counterparty relationships using blockchain analytics tools (e.g., Elliptic, Chainalysis, TRM) Monitor for changes in customer circumstances, employment status, business activities, or geographic exposure
Risk Assessment & Documentation
Reassess customer risk ratings based on updated information, transaction behavior, and external risk factors Analyze ongoing source of funds (SOF), transaction patterns, wallet behavior, and exposure to high-risk counterparties Review and validate changes in customer information, employment details, and account usage patterns Track sanctions screening results, adverse media, and reputational risks on an ongoing basis
Reporting & Escalation
Draft comprehensive ODD reports with updated risk assessments and actionable recommendations (continue, enhance monitoring, restrict, or exit) Escalate material changes in risk profile, suspicious patterns, or regulatory concerns to Senior Compliance and MLRO Identify and escalate potential suspicious activity (SAR/STR triggers) discovered during ongoing reviews Maintain accurate and timely records in internal case management systems
Compliance & Quality Standards
Adhere to ODD review schedules, SLAs, and internal Standard Operating Procedures (SOPs) Ensure all ongoing due diligence activities meet regulatory requirements and internal QA standards Support internal and external audits by providing documentation and case rationale Stay current on regulatory updates, emerging typologies, and industry best practices
Required Skills & Qualifications
2–4+ years of experience in AML Compliance, Financial Crime, or Ongoing Due Diligence, preferably in crypto, fintech, or retail banking Strong knowledge of AML/CFT regulations, ongoing CDD requirements, and risk-based monitoring frameworks Understanding of sanctions frameworks (OFAC, UN, EU, HMT), PEP definitions, and adverse media screening Solid understanding of blockchain technology, cryptocurrency wallets, transaction flows, and on-chain analysis