Deputy AMLO Payments

About the role

As a Deputy AMLO at Bybit, you will support the MLRO in implementing AML/CTF policies in line with regulatory frameworks. Your responsibilities will include overseeing client due diligence, managing suspicious transaction reports, and conducting risk assessments for investment firm clients.

You will work within a global team committed to compliance and innovation, ensuring that Bybit maintains its reputation as a trusted cryptocurrency exchange. Success in this role involves effective collaboration with various departments and a proactive approach to compliance training and regulatory reporting.

Skills that matter here

• AML: This role involves implementing and maintaining AML policies to ensure compliance with regulations.
• CTF: You will oversee CTF measures and monitor transaction activities to prevent financial crimes.
• KYC: KYC processes will be crucial for assessing client appropriateness and risk.
• compliance: You will ensure adherence to compliance standards across Bybit's operations.
• financial services: Experience in financial services is essential for understanding regulatory requirements.
• fintech: Knowledge of the fintech landscape will help in navigating compliance challenges specific to digital finance.

Who this role suits

• Candidates should have a strong background in AML/CTF compliance, ideally within the fintech or financial services sector.
• A detail-oriented individual who can manage complex regulatory requirements and maintain high standards of accuracy.
• Someone who thrives in a fast-paced, collaborative environment and is committed to continuous learning and professional development.
• Fluency in English is essential, and knowledge of German is advantageous for regulatory communications.

From the employer

Key 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, 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

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

Why Join Us

• 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.