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Bybit is a leading global cryptocurrency exchange and digital financial platform serving over 80 million users across 200+ countries. Bybit X GmbH is the MiFID II investment firm entity of the Bybit EU Group, operating as a fully regulated Austrian financial services company under FMA supervision.
This is a named key function holder role supporting the MLRO (Money Laundering Reporting Officer) in fulfilling all anti-financial crime obligations for an FMA-supervised investment firm. The Deputy AMLO operates at the intersection of two compliance frameworks: AML/CTF under FM-GwG (Austrian AML Act) and MiFID II/WAG 2018 investment firm requirements.
**Key Responsibilities:**
AML/CTF Compliance: Support implementation and maintenance of AML/CTF policies compliant with FM-GwG, EU AMLD6, and FMA guidance. Oversee customer due diligence (CDD), enhanced due diligence (EDD), and ongoing monitoring for investment firm clients. Act as deputy responsible person (verantwortliche Person) under FM-GwG § 9, maintaining regulatory standing and continuing education. Manage suspicious transaction reports (STR) and suspicious activity reports (SAR) to the Austrian A-FIU (Geldwäschemeldestelle), maintain SAR registers, and ensure tipping-off prevention. Handle law enforcement requests and sanctions obligations under EU Sanctions Regulation and FM-GwG screening requirements. Conduct and document risk assessments for investment firm products, clients, and distribution channels. Oversee product governance including product approval processes, target market definition, and distributor feedback.
Quality Assurance & Second Line of Defence: Independently review KYC/KYB files and client onboarding 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.
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 receive AFC training.
Regulatory Liaison & Reporting: Act as deputy contact point with the FMA for WAG 2018 licensing matters, improvement orders, and supervisory requests. Assist with preparation and submission of regulatory reports (MLRO annual report, AML/CTF risk assessments, management body compliance reports). Support Fit & Proper 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. 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 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 as 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, Fit & Proper submissions, improvement orders). Experience with derivatives, leveraged products, or crypto-asset services. Understanding of MAR (Market Abuse Regulation) and its intersection with AML monitoring.
