Principal, Internal Audit (SOX Program)

About the Company

Gemini is a global crypto and Web3 platform founded by Cameron and Tyler Winklevoss in 2014, offering a wide range of simple, reliable, and secure crypto products and services to individuals and institutions in over 70 countries. Our mission is to unlock the next era of financial, creative, and personal freedom by providing trusted access to the decentralized future. We envision a world where crypto reshapes the global financial system, internet, and money to create greater choice, independence, and opportunity for all — bridging traditional finance with the emerging cryptoeconomy in a way that is more open, fair, and secure. As a publicly traded company, Gemini is poised to accelerate this vision with greater scale, reach, and impact.

The Department: Internal Audit

Internal Audit at Gemini is dedicated to providing independent assurance of the design and effectiveness of internal controls while working with business partners to solve problems and optimize the control environment for continued growth.

The Role: Principal, Internal Audit (SOX Program)

Reporting to the Global Head of Internal Audit, this individual is responsible for managing Gemini’s Sarbanes-Oxley (SOX) testing program. The role's primary responsibilities include evaluating Gemini’s controls over financial reporting and compliance with SOX and other key regulations, managing third-party consultants, collaborating with the Finance department and external auditors on control testing activities, and partnering with key stakeholders to design remediation solutions for identified issues. This individual has a unique opportunity to help build an innovative and efficient SOX program as part of a modern Internal Audit department in the evolving, fast-paced digital assets industry.

The Principal, Internal Audit (SOX Program) will oversee, manage, and monitor Gemini’s SOX testing program as well as partner with business departments in enhancing controls over financial reporting and improving core processes. This individual will scope and execute SOX testing, partner with process owners to develop remediation plans for control gaps and deficiencies, monitor and validate the remediation of gaps and deficiencies, and promote sustainable financial reporting processes through a SOX testing program. Internal Audit is one of the few functions that has the opportunity to make an impact on all lines of business to ensure critical processes are well controlled. The ideal candidate is a strong critical thinker, adaptive to evolving regulatory environments and emerging risks, has an open and creative mindset on how to approach risk within a rapidly changing environment, and communicates effectively with leadership.

This role is required to be in person twice a week at either our San Francisco, CA or New York City, NY office.

Responsibilities:

• Oversee the SOX testing program in accordance with professional standards, company policies, and regulatory requirements. This includes annual and ongoing scoping, controls testing to identify control gaps and deficiencies, and reporting of results related to SOX activities, as well as oversight of third-party consultants in the execution of these activities.
• Manage and execute testing of IT General Controls and IT Application Controls for coverage over automated and IT-dependent Internal Controls over Financial Reporting (ICFR) processes.
• Coordinate with external auditors on SOX testing, evidence collection and related efforts to align on control assessments and findings and maximize efficiency of the SOX program.
• Contribute to and evaluate methods to streamline audit approaches, improve control testing activities, and enhance monitoring and reporting on ICFR and SOX activities.
• Work closely with control owners and stakeholders to provide meaningful input on effective control design and implementation, and deficiency remediation, while maintaining the independence of the third line of defense.
• Collaborate with management on an ongoing basis to facilitate timely remediation of control gaps and deficiencies through monitoring and reporting of remediation progress and effectiveness to Senior Management.
• Facilitate the SOX risk assessment process, including the identification and scoping of SOX controls in coordination with the broader global Internal Audit risk assessment.
• Develop and deliver reporting on SOX testing results, themes and trends and status of related activities to Senior Management and the Audit and Risk Committee.
• Collaborate with internal functions and stakeholders on SOX walkthroughs, process documentation and control testing evidence and activities.
• Communicate and educate stakeholders on standards for data integrity and overall documentation as required for Management Review Controls and Information Provided by the Entity to demonstrate data completeness, accuracy, and validation.
• Drive the implementation of AuditBoard’s SoxHub to track and retain controls testing and remediation; as well as, develop and adopt automated testing, data analytics and/or the use of technology to optimize the SOX program.

Qualifications:

• 8+ years of financial services, fintech, or cryptocurrency internal audit, external audit, ICFR/SOX experience with increasing responsibility.
• 4+ years leading an audit team.
• Prior experience managing and reporting on an ICFR/SOX testing program including risk assessment, scoping, control design and implementation, testing approach, deficiency evaluation, and remediation oversight.
• Strong understanding of business process controls and IT Controls (IT General Controls and IT Application Controls).
• Working knowledge of US GAAP, SOX 404 requirements, COSO framework, PCAOB auditing standards and relevant SOC  reporting  standards, as well as other procedures, laws, rules and regulations.
• Ability to be flexible in a rapidly changing risk and regulatory environment and “roll up sleeves” when priorities or project scopes change.
• Ability to lead a project team and foster a strong working relationship with in-house auditors, third-party co-sourcing providers, regulators, and internal lines of businesses.
• Strong verbal and written communication skills.
• Proven ability to meet project budget and timeline constraints, and to identify and escalate issues that may impact project progress.
• Creative mindset that will allow effective challenge on how the internal audit program and specific internal audit projects are performed to promote continuous improvement.
• Strong organizational skills and proven ability to effectively manage and prioritize time amongst various activities.
• Bachelor’s degree in Accounting, Finance, Information Systems, Risk Management or related field, or commensurate work experience.

• Competitive starting salary
• A discretionary annual bonus
• Long-term incentive in the form of a new hire equity grant
• Comprehensive health plans
• 401K with company matching
• Paid Parental Leave
• Flexible time off

Salary Range: The base salary range for this role is between $129,500 - $185,000 in the State of New York, the State of California and the State of Washington. This range is not inclusive of our discretionary bonus or equity package. When determining a candidate’s compensation, we consider a number of factors including skillset, experience, job scope, and current market data.

In the United States, we offer a hybrid work approach at our hub offices, balancing the benefits of in-person collaboration with the flexibility of remote work. Expectations may vary by location and role, so candidates are encouraged to connect with their recruiter to learn more about the specific policy for the role. Employees who do not live near one of our hubs are part of our remote workforce.

At Gemini, we strive to build diverse teams that reflect the people we want to empower through our products, and we are committed to equal employment opportunity regardless of race, color, ancestry, religion, sex, national origin, sexual orientation, age, citizenship, marital status, disability, gender identity, or Veteran status. Equal Opportunity is the Law, and Gemini is proud to be an equal opportunity workplace. If you have a specific need that requires accommodation, please let a member of the People Team know.

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