[EU] Deputy AMLO Payments

About Us
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. Powered by world-class technology and a user-first mindset, Bybit delivers a seamless ecosystem across trading, payments, wealth management, custody, institutional services, and Web3 — connecting users to the future of digital finance.
Our core values define how we build. We listen, care and improve to create products and experiences that put users first. Backed by a global team of ambitious builders, problem-solvers, and innovators, we foster a high-performance and fast-moving environment where talent is empowered to drive real impact at the global scale. Supported by 24/7 multilingual customer service and a strong commitment to innovation, we are shaping the future of finance through technology, collaboration, and bold execution.
Today, Bybit is recognized as one of the most trusted and transparent platforms in the digital asset industry, continuing to expand its global presence while building the infrastructure for the next generation of financial services.
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