[EU] Deputy AMLO Payments

Established in 2018, Bybit is one of the world’s leading cryptocurrency exchanges and digital financial platforms, serving over 80 million users across more than 200 countries and regions. Powered by world-class technology and a user-first mindset, Bybit delivers a seamless ecosystem across trading, payments, wealth management, custody, institutional services, and Web3 — connecting users to the future of digital finance.

Bybit X GmbH is the MiFID II investment firm entity of the Bybit EU Group, applying to the FMA for authorisation under WAG 2018. Bybit X will serve as the sole contractual counterparty for all derivative contracts concluded on the Bybit EU platform, providing investment services to EU clients. Operating alongside Bybit EU GmbH (CASP/MiCA) and Bybit Payments GmbH (EMI), Bybit X is part of a fully regulated Austrian financial services group committed to the highest standards of compliance and investor protection.

The Deputy MLRO (Deputy AMLO) at Bybit X GmbH supports the MLRO in fulfilling all anti-financial crime obligations applicable to an FMA-supervised investment firm. This is a named key function holder role subject to FMA fit & proper assessment under WAG 2018 and FM-GwG.

Responsibilities

• Support the MLRO in implementing and maintaining AML/CTF policies and procedures compliant with FM-GwG, the EU AMLD framework, and applicable FMA guidance
• Oversee CDD, EDD, and ongoing monitoring for investment firm clients, including appropriateness assessments intersecting with KYC data
• Act as deputy responsible person (verantwortliche Person) under FM-GwG § 9 — maintain regulatory standing and continuing education requirements per FMA expectations
• Manage STR/SAR submissions to the Austrian A-FIU (Geldwäschemeldestelle); maintain SAR register; ensure tipping-off prevention
• Handle law enforcement requests and sanctions-related obligations (EU Sanctions Regulation, FM-GwG screening requirements)
• Conduct and document risk assessments for investment firm products, clients, and distribution channels
• Product governance: product approval process, target market definition, distributor feedback
• Independently review KYC/KYB files and client onboarding and risk assessment processes from an investment firm perspective
• Conduct regular QA reviews of AML/CTF controls, transaction monitoring and SAR processes
• Develop and track KPIs/KRIs for AFC compliance activities
• Perform quarterly self-assessments per Bybit EU Group AML Minimum Control Standards
• Oversee transaction monitoring for suspicious activity in investment firm activities (derivatives, spot, custody)
• Collaborate with operations and technology teams on monitoring system enhancements and rule testing
• Develop and deliver AML/CTF compliance training
• Maintain personal continuing education
• Ensure all relevant staff are trained on AFC requirements
• Act as deputy contact point with the FMA for WAG 2018 licensing matters, improvement orders, and ongoing supervisory requests
• Assist with preparation and submission of regulatory reports (MLRO annual report, AML/CTF risk assessments, management body compliance reports)
• Support F&P documentation requirements for own position and other key function holders
• Co-own the AML/CFT Policy, Sanctions Policy, Compliance Policy, and related procedures applicable to Bybit X GmbH
• Support the group-wide AML Minimum Control Standards framework as applicable to the MiFID entity
• Participate in vendor and outsourcing oversight for AML/CTF-related third-party services

Requirements

• Bachelor's degree or higher in Law, Finance, Business Administration, Economics, or a related field
• Minimum 4–6 years of experience in AML/CTF, KYC compliance, or securities compliance within financial services, investment firms, or fintech
• Strong working knowledge of: FM-GwG (Austrian AML Act) and EU AMLD6; WAG 2018 and MiFID II organisational/conduct requirements; FMA supervisory practices
• Proven experience in a second-line-of-defence compliance or AML officer role
• Ability to pass FMA fit & proper assessment: reliability (Zuverlässigkeit), professional qualification (fachliche Eignung), and sufficient time commitment — per WAG 2018 § 5 and FM-GwG § 9
• Fluency in English (working language); German is a strong advantage — FMA correspondence and licensing submissions are conducted in German
• Clean criminal record (required for FM-GwG § 9 responsible person appointment)
• The Deputy MLRO must be capable of supporting both dimensions, either in a combined role (if independence requirements under WAG 2018 Art. 29 / ESMA guidelines are met) or in close coordination with the WAG 2018 Compliance Officer.
• Nice to have: AML/CTF professional certification: ACAMS, ICA Certificate/Diploma in AML, or equivalent
• Nice to have: Prior experience as a named Deputy AMLO, Deputy MLRO, or WAG 2018 compliance officer at an FMA-licensed entity
• Nice to have: Knowledge of MiFID II product governance, suitability, and investor protection frameworks
• Nice to have: Familiarity with Austrian FMA licensing processes (WAG 2018 applications, F&P submissions, improvement orders)
• Nice to have: Experience with derivatives, leveraged products, or crypto-asset services
• Nice to have: Understanding of MAR (Market Abuse Regulation) and its intersection with AML monitoring

Benefits

• Study Growth Fund: We support your professional development and continuous learning.
• Internal Events: Participate in regular team-building activities, workshops, and events designed to promote collaboration and innovation.
• Global Collaboration: Be part of a diverse, international team, working alongside colleagues from around the world.
• Career Advancement: Access opportunities for growth and advancement within a rapidly expanding global company.
• Internal Mobility: Grow with us- Your long-term development is important to us. We offer internal job opportunities to help build your career path.

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