[EU] Deputy AMLO Payments

As Deputy AMLO (Deputy MLRO) at Bybit X GmbH, you support 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 and proper assessment under WAG 2018 and FM-GwG. You operate at the intersection of AML/CTF compliance under FM-GwG and MiFID II/WAG 2018 compliance, supporting both dimensions either in a combined role or in close coordination with the WAG 2018 Compliance Officer.

What you'll do

• 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 under FM-GwG § 9, maintaining regulatory standing and continuing education requirements per FMA expectations
• Manage STR/SAR submissions to the Austrian A-FIU (Geldwäschemeldestelle), maintain SAR register, and ensure tipping-off prevention
• Handle law enforcement requests and sanctions-related obligations under EU Sanctions Regulation and FM-GwG screening requirements
• Conduct and document risk assessments for investment firm products, clients, and distribution channels
• Support product governance including product approval processes, target market definition, and 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 anti-financial crime compliance activities
• Perform quarterly self-assessments per Bybit EU Group AML Minimum Control Standards
• Oversee transaction monitoring for suspicious activity in investment firm activities including derivatives, spot, and custody
• Collaborate with operations and technology teams on monitoring system enhancements and rule testing
• Develop and deliver AML/CTF compliance training and maintain personal continuing education
• Ensure all relevant staff are trained on anti-financial crime 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 including MLRO annual report, AML/CTF risk assessments, and management body compliance reports
• Support fit and proper documentation requirements for your 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

What you bring

• 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 and conduct requirements, and FMA supervisory practices
• Proven experience in a second-line-of-defence compliance or AML officer role
• Ability to pass FMA fit and 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 as FMA correspondence and licensing submissions are conducted in German
• Clean criminal record (required for FM-GwG § 9 responsible person appointment)

Nice to have

• AML/CTF professional certification such as ACAMS or ICA Certificate/Diploma in AML, or equivalent
• Prior experience as a named Deputy AMLO, Deputy MLRO, or WAG 2018 compliance officer at an FMA-licensed entity
• Knowledge of MiFID II product governance, suitability, and investor protection frameworks
• Familiarity with Austrian FMA licensing processes including WAG 2018 applications, fit and proper submissions, and improvement orders
• Experience with derivatives, leveraged products, or crypto-asset services
• Understanding of MAR (Market Abuse Regulation) and its intersection with AML monitoring

What we offer

• Study Growth Fund supporting your professional development and continuous learning
• Internal Events including regular team-building activities, workshops, and events designed to promote collaboration and innovation
• Global Collaboration as part of a diverse, international team working alongside colleagues from around the world
• Career Advancement with opportunities for growth within a rapidly expanding global company
• Internal Mobility and long-term development support, with internal job opportunities to help build your career path

About Bybit

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