Deputy AMLO MiFID

About Us

• 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

• 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

• 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)

• 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

Why Join Us
At Bybit, we are committed to fostering a supportive and enriching work environment. 
Our benefits include:
- 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.