Eight Questions: Mark duBose, Chief Compliance and Risk Officer, Anchorage Digital Bank

Welcome to Eight Questions, where we profile individual members of the Anchorage Digital team, diving into their career paths, what brought them to crypto, and what makes them tick. Why eight? Because it’s the number of decimal places a bitcoin can be divided into. It’s also the last single digit number in a Fibonacci Sequence, and we like that.

Leslie Ankney

Next in our series, meet Mark duBose, Anchorage Digital Bank’s Chief Compliance and Risk Officer and a longtime leader in compliance and risk. An Army veteran, he holds a J.D. and an MBA from Wake Forest University. Mark is based in Boston and enjoys skiing and hiking with his family outside of work.

1. When you joined us in January 2023, it was the two-year anniversary of our charter from the OCC. What are some of your observations about the company since then?

Being the only national trust bank in crypto makes Anchorage Digital Bank—quite literally—the most regulated crypto company on earth. Since joining, I’ve seen and played a part as Anchorage Digital has increased its commitment to being strong at regulation. With both humility and confidence, we embrace all that comes with that. In the past five months, the advancements and maturity of our compliance programs overwhelmingly and very measurably reflect that commitment.

2. We announced your joining as part of our work to level up our Compliance team and Anchorage Digital Bank. What are some of your goals for the bank and compliance program?

Anchorage Digital has the industry-leading security tech stack and, as noted above, an unmatched “reg stack.” For customers who prefer or require one or both of those, Anchorage Digital has a huge competitive advantage. My goal for the bank is simply that we continue to find ways to most efficiently and seamlessly bring those capabilities to customers. My goals for Compliance are, first, naturally to meet our immediate and ongoing compliance commitments and, second, to develop the highest performing team that is relentless in pursuing ways for us to become more effective in compliance and risk management and contributing, each in our own way, to accomplishing our mission.

3. What’s your leadership style like? How do you engage and empower your team?

As a leader and manager, I want my team members to be fulfilled and successful in their roles and ultimately their careers. I do this in four ways:

• First, make clear everyone understands our vision and strategy.
• Second, create relentless clarity in accountability and ownership. (I think most companies struggle with this, by the way.)
• Third, share frequent positive and constructive feedback. Everyone can always get better at their job.
• Fourth, encourage and empower teammates to constantly look to where they can be put to their highest and best use.

4. How has your conception of risk management evolved over the course of your career?

My conception of risk management hasn’t been an evolution as much as a reaffirmation of core practices that are critical, regardless of company size and complexity or program maturity. To avoid the risk that programs become check-the-box exercises, financial services companies should make sure they have the following foundations in place:

• Risk and Compliance need to understand the business.
• Often the best risk identification tool is the simple question, “What keeps you up at night?” Then, don’t neglect these risks just because your risk programs haven’t caught up to identifying them.
• Lastly, to avoid diffusion of accountability, there absolutely should be only one designated control owner (with backup plans and support).

5. If you could will one thing about compliance, risk and banking processes into existence across the board at every company, what would it be? Why?

I would hammer home that the Board, not individuals, sets risk appetite. So, any risk-related business decision should be measured against that appetite, not an individual’s. If the parties are measuring against that standard, any claim that the “Risk team is being too risk averse” or “the Business team is being too risky” would be avoided. Everybody understands this at Anchorage Digital, and we get to the right decisions more quickly because of it.

6. What kind of movement have you seen on the part of other crypto-native companies to operate more like traditional banks?

Many crypto companies in the U.S. are money service businesses, so they have programs to comply with AML/Sanctions laws. Otherwise, with only a few exceptions you don’t see many crypto-native companies adopting bank-like, right-sized risk programs.

Sadly, there are plenty of examples of failed crypto companies that lacked risk management discipline. A big part of my decision to join Anchorage Digital was its regulatory commitment and the opportunity it presented for me and the team I lead to show crypto could be compliant and fit within the existing bank regulatory perimeter. Risk management is really just a part of informed business decision-making.

7. What is the biggest way to make crypto an enduring part of the financial system?

Clearer regulation to remove uncertainty, especially around market structures, digital asset classifications, and customer disclosure requirements. U.S. agencies need to stop legislating by enforcement.

8. You served in the Army, graduating from the demanding Airborne School and as a member of the Judge Advocate General’s Corps. Are there lessons from your time in the military you apply today?

The biggest lesson is the importance of teamwork, each of us contributing in our own way to the accomplishment of the mission. (At Anchorage Digital, it’s no accident that we think of ourselves as a “Village.”) Also, there are few organizations as obsessive about controls and processes as the U.S. military. That discipline in controls in the military carries over to how I think about the repeatability and sustainability of controls in banking. (A former Army paratrooper, even at age 90, would immediately know what to do if his parachute failed to open.) That same continual focus on execution and repetition, doing something well over and over again, is an enduring lesson for me.

Interested in working with Mark and the Anchorage Digital Compliance team? Anchorage Digital is hiring, check our job opportunities here.