Deputy AMLO MiFID

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; Act as deputy responsible person (verantwortliche Person) under FM-GwG § 9; Manage STR/SAR submissions to the Austrian A-FIU and maintain SAR register; Handle law enforcement requests and sanctions-related obligations; 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; 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; 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; 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; Clean criminal record (required for FM-GwG § 9 responsible person appointment)

Nice to have

Professional AML/CTF 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

Benefits

Study Growth Fund for professional development and continuous learning; Internal Events: regular team-building activities, workshops, and events; Global Collaboration within a diverse, international team; Career Advancement opportunities within a rapidly expanding global company; Internal Mobility: internal job opportunities to build your career path