Onbudsman Officer

About the CompanyBybit 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 OverviewThe 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-FIUMiFID II / WAG 2018 compliance function —
investor protection, conduct, product governance, and organisational requirementsThe 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 Responsibilities1. AML/CTF ComplianceSupport the MLRO in implementing and maintaining AML/CTF policies and procedures compliant with FM-GwG, the EU AMLD framework, and applicable FMA guidanceOversee CDD, EDD, and ongoing monitoring for investment firm clients, including appropriateness assessments intersecting with KYC dataAct as deputy responsible person (verantwortliche Person) under FM-GwG § 9 — maintain regulatory standing and continuing education requirements per FMA expectationsManage STR/SAR submissions to the Austrian A-FIU (Geldwäschemeldestelle);
maintain SAR register;
ensure tipping-off preventionHandle 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 channelsProduct governance: product approval process, target market definition, distributor feedback
2. Quality Assurance & Second Line of DefenceIndependently review KYC/KYB files and client onboarding and risk assessment processes from an investment firm perspectiveConduct regular QA reviews of AML/CTF controls, transaction monitoring and SAR processesDevelop and track KPIs/KRIs for AFC compliance activitiesPerform quarterly self-assessments per Bybit EU Group AML Minimum Control Standards
4. Transaction MonitoringOversee 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
5. Training & AwarenessDevelop and deliver AML/CTF compliance trainingMaintain personal continuing educationEnsure all relevant staff are trained on AFC requirements
6. Regulatory Liaison & ReportingAct as deputy contact point with the FMA for WAG 2018 licensing matters, improvement orders, and ongoing supervisory requestsAssist 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
7. Policy, Governance & Vendor ManagementCo-own the AML/CFT Policy, Sanctions Policy, Compliance Policy, and related procedures applicable to Bybit X GmbHSupport the group-wide AML Minimum Control Standards framework as applicable to the MiFID entityParticipate in vendor and outsourcing oversight for AML/CTF-related third-party services
RequirementsMandatoryBachelor's degree or higher in Law, Finance, Business Administration, Economics, or a related fieldMinimum 4–6 years of experience in AML/CTF, KYC compliance, or securities compliance within financial services, investment firms, or fintechStrong working knowledge of: FM-GwG (Austrian AML Act) and EU AMLD6;
WAG 2018 and MiFID II organisational/conduct requirements;
FMA supervisory practicesProven experience in a second-line-of-defence compliance or AML officer roleAbility to pass FMA fit & proper assessment: reliability (Zuverlässigkeit), professional qualification (fachliche Eignung), and sufficient time commitment — per WAG 2018 § 5 and FM-GwG § 9Fluency in English (working language);
German is a strong advantage — FMA correspondence and licensing submissions are conducted in GermanClean criminal record (required for FM-GwG § 9 responsible person appointment)
PreferredAML/CTF professional certification: ACAMS, ICA Certificate/Diploma in AML, or equivalentPrior experience as a named Deputy AMLO, Deputy MLRO, or WAG 2018 compliance officer at an FMA-licensed entityKnowledge of MiFID II product governance, suitability, and investor protection frameworksFamiliarity with Austrian FMA licensing processes (WAG 2018 applications, F&P submissions, improvement orders)Experience with derivatives, leveraged products, or crypto-asset servicesUnderstanding of MAR (Market Abuse Regulation) and its intersection with AML monitoring