Director of Cybersecurity & Incident Response (Brazil)

Key Responsibilities

• Design, implement and maintain the Cybersecurity Policy, the Incident Response Plan, and the Cloud Services Contracting Policy, in line with BCB Resolution 85/2021 and BCB Resolution 520/2025.
• Oversee the protection of private keys and the custody architecture (cold/hot/warm wallets, MPC, multisig, HSM).
• Lead the security operations function (SOC/SIEM, threat intelligence, vulnerability management, pentests, red-team).
• Ensure timely reporting of relevant incidents to the BCB, ANPD (LGPD) and other authorities, and coordinate post-incident remediation.
• Manage third-party and cloud risk (vendor due diligence, contractual safeguards, BCB notification regime for relevant IT contracts).
• Integrate cybersecurity into the broader risk framework alongside the Risk, Compliance, AML and IT functions.
• Build and lead the cybersecurity team; embed a security-by-design culture.
• Represent the company before regulators, auditors and the Board on cybersecurity matters.

Mandatory Requirements

• Brazilian residency (mandatory for statutory directors of BCB-regulated entities).
• Unblemished reputation, no criminal convictions in the offences listed in Article 11 of BCB Resolution 519/2025, no current disqualification or suspension in any regulated financial institution, no bankruptcy, no BCB rejection in the past three years.
• Demonstrated technical capacity and knowledge of the cybersecurity domain compatible with BCB Normative Instruction 712/2025 and CMN Resolution 4,970/2021 fit & proper standards.
• Willingness to undergo BCB authorisation procedures and ongoing supervisory scrutiny.

Qualifications

• Bachelor's degree in Computer Science, Information Security, Engineering or equivalent; postgraduate degree preferred.
• 10+ years of cybersecurity experience, with at least 5 years in leadership roles within financial institutions, fintechs, crypto exchanges or critical-infrastructure environments.
• Hands-on expertise in: cryptographic key management, blockchain and smart-contract security, cloud security (AWS/GCP), SOC operations, DLP, IAM/PAM, threat modelling, incident response and digital forensics.
• Working knowledge of BCB Resolution 85/2021, BCB Resolution 520/2025, LGPD (Law 13,709/2018), ISO 27001, NIST CSF 2.0 and PCI DSS.
• Industry certifications such as CISSP, CISM, CCSP, CCSK, CISA or equivalent.
• Fluent Portuguese and advanced English.

Differentiators

• Prior experience as a statutory officer in a BCB or CVM-regulated institution.
• Experience supporting a BCB authorisation process or implementing a cybersecurity programme from the ground up.
• Direct experience in crypto-asset exchanges, custodians or wallet providers.
• Familiarity with international VASP frameworks (FATF, MAS, MiCA).