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This position services the position requirements of both iFinex, Tether Holding Limited, (‘the Companies’) and applicable subsidiaries. The position reports to the Chief Compliance Officer and a dotted line to the Head of Licensing and Internal Compliance Testing of iFinex and Tether.

The primary purpose of this position is two-fold:

(1) To support the ongoing design, enhancement and execution of the Companies’internal money laundering (“ML”) / terrorist financing (“TF”) and sanctions risk assessment for both the business and its customers. This includes helping to execute the ML/TF Sanction risk assessment across the Companies’ products and business lines, evaluating inherent risk associated with customers, products, services and geographic locations; providing input, support the maintenance and enhancement opportunities to improve the ML/TF/Sanctions risk framework including the risk assessment methodology and standards; and providing advice and direction to applicable business lines, educating them on ML/TF/Sanctions risk and acting as an advisor to risk owners in the Companies.

(2) In support of the Companies’ risk assessment activities, and as part of supporting the assessment of Program effectiveness, the incumbent will be responsible for working with the Chief Compliance Officer to support the build- out and execution of an internal compliance testing / quality assurance program across the Companies and their affiliates. This will include performing testing quality assurance activities to assess the design and operating effectiveness of the Companies’processes and controls.

The incumbent will work in seamless partnership with the Chief Compliance Officer or designate of the Companies in helping to develop, implement and execute the internal risk assessment program consistent with applicable laws, regulations, and best practices, together with supporting policies, procedures, and training. The incumbent will play an important role in working to proactively identify internal and

external AML risk drivers, AML risk mitigants and support the development of action plans to manage AML risk across the Companies’ various products and business lines.

The internal testing responsibilities will act as a key line of defense and help ensure the effectiveness of the Companies’ anti-money laundering (AML)/ anti-terrorist financing (ATF) controls as well as ongoing compliance of economic sanctions, policies, standards and regulatory requirements. The incumbent will provide support to the AML Programs and will contribute to the overall success of the Companies’ by

helping to identify control weaknesses and make recommendations to the Head of Licensing and Internal Compliance Testing and the Chief Compliance Officers to improve or enhance current processes and controls. Where control gaps are identified, the incumbent assist in liaising with Company project managers and developers to design solutions and help to update policies and procedures documents in relation to gap remediation.

The Manager will have interactions with a broad range of internal stakeholders across the Companies’ as part of this role, working closely with members of the On-boarding, Investigations, Security and Customer Support Teams in the Companies.

In performing the role, the incumbent will strive to continuously self-develop and enhance their skill sets including understanding blockchain technology and virtual assets. Additionally, building and maintaining current, detailed knowledge of AML matters including AML risk drivers and typologies, AML and Sanctions regulatory requirements and best practices related to the risk assessment process and risk mitigation in the virtual asset space.

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In addition to the skill set preferred requirements listed below the incumbent must be able to work independently with minimum supervision, be flexible as to working arrangements and hours and confident in communicating findings/updates to peers and colleagues.

Knowledge / Experience:

o University education (Preferred).

o CAMS or equivalent, CBP / blockchain analysis designation or equivalent (Preferred).

o Experience in one or more of the following areas: ML/TF/Sanctions risk assessment and/or Investigations, Audit / Testing / Internal Controls in either traditional or virtual asset environments.

o Experience in leading or participating in Project Management (preferred).

Skills:

o Resourceful operator; able to think around problems and form effective solutions.

o Inquisitive mindset.

o Excellent people skills and strong written and verbal communications skills are essential to effectively drive solutions across a diverse workforce in different locations. Excellent English written and verbal communication skills are also necessary.

o Demonstrated critical-thinking skills, (decision-making).

o Organizational understanding.