[EU] Deputy AMLO Payments

About the Company

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.

Position Overview

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.

The role sits at the intersection of two distinct compliance frameworks:

AML/CTF under FM-GwG — the MLRO function, including STR reporting to the Austrian A-FIU

MiFID II / WAG 2018 compliance function — investor protection, conduct, product governance, and organisational requirements

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.

Key Responsibilities

AML/CTF Compliance

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

Quality Assurance & Second Line of Defence

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

Transaction Monitoring

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

Training & Awareness

Develop and deliver AML/CTF compliance training

Maintain personal continuing education

Ensure all relevant staff are trained on AFC requirements

Regulatory Liaison & Reporting

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

Policy, Governance & Vendor Management

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

Mandatory

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)

Preferred

AML/CTF professional certification: ACAMS, 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 (WAG 2018 applications, F&P submissions, improvement orders)

Experience with derivatives, leveraged products, or crypto-asset services

Understanding of MAR (Market Abuse Regulation) and its intersection with AML monitoring