Anti-Money Laundering Officer

What will you do

As the Anti-Money Laundering Officer you are the designated key function holder responsible for establishing, managing, and continuously improving all policies, systems, and processes to counter the risks of the Company's involvement in money laundering, terrorism financing, bribery, and corruption. You will serve as the central point of contact — both internally and externally — for all matters related to AML/CFT compliance.

This role is established in accordance with the Austrian Financial Market Anti-Money Laundering Act (FM-GwG), MiCAR (Regulation (EU) 2023/1114), the Austrian MiCA-VVG, and the FMA's published governance requirements for obliged entities.

Your key responsibilities include:

• AML/CFT Framework & Compliance: Design, implement, and maintain the AML/KYC/CFT compliance framework across all business functions. Develop and update internal policies, procedures, and controls while monitoring regulatory developments to ensure sustained compliance with Austrian and EU requirements.

• Risk Management: Conduct and maintain the Company's Money Laundering/Terrorist Financing Risk Assessment. Identify risks related to customers, geographies, and products, and implement enhanced due diligence (EDD) measures for high-risk scenarios (PEPs, complex structures, high-risk jurisdictions).

• Monitoring & Detection: Oversee behavior and transaction monitoring systems. Supervise the implementation and effectiveness of automated monitoring tools and alert management to adequately detect unusual or suspicious activities.

• Reporting & Regulatory Liaison: Act as the primary liaison with the Austrian Financial Intelligence Unit (A-FIU at the Federal Ministry of the Interior). File Suspicious Transaction Reports (STRs) independently of management instructions. Report at least quarterly to the Board of Directors via formal compliance updates.

• Sanctions Compliance: Oversee sanctions screening processes and systems to ensure alignment with applicable EU and national sanctions regimes, coordinating closely with the Sanctions Officer.

• Training & Awareness: Design, implement, and oversee AML/CFT training programs for all staff to promote cross-organizational awareness of obligations and red flags.

• Outsourcing Oversight: Supervise and control all outsourced AML/CFT functions, including shared AML services at the AT Holding level and third-party tools, ensuring compliance is never impaired.

• Second Line of Defense: Lead and supervise the second line of defense regarding AML/CTF, bribery, and corruption. Work in close cooperation with the Second Co-CEO on compliance matters and coordinate with the COO on client onboarding and KYC processes.

What should you bring

• Adequate Professional Experience: Minimum 5 years in AML/CFT compliance, preferably in financial services or the crypto-asset industry.

• Expert Qualification: Demonstrated through relevant education and internationally recognized certifications (e.g., CAMS, ICA Diploma).

• Senior Positioning & Reputation: Sufficient seniority and authority within the organization, backed by a good personal reputation (Zuverlässigkeit), proven integrity, and a clean criminal record relevant to the function.

• FMA-Notifiable: Readiness for an FMA-notifiable appointment (the FMA must be notified prior to appointment and retains the right to revoke based on qualifications/reliability criteria).

Knowledge & Expertise:

• Deep knowledge of Austrian AML/CFT legislation (FM-GwG, BWG, WiEReG).

• Comprehensive understanding of the EU regulatory framework (MiCAR, AMLD 4/5/6, Transfer of Funds Regulation) and FATF standards.

• Familiarity with crypto-asset-specific ML/TF typologies, risks, and international sanctions regimes (EU, UN, OFAC).

Skills & Competencies:

• Strong leadership, risk-based thinking, and stakeholder management skills with the ability to communicate complex regulatory matters to senior executives and the board.

• Experience utilizing modern AML/CFT technology solutions (transaction monitoring, automated screening tools).

• Fluency in English is required; German is highly preferred.

Desirable Assets:

• Prior compliance experience in a CASP (Crypto Asset Service Provider) or fintech environment.

• Hands-on experience with regulatory examinations, FMA interactions, or building AML programs from scratch during licensing processes.

Join us and be part of shaping the future of finance and technology.