MLRO & Compliance Officer, UAE (ADGM) - RIE & RCH

Role Overview

MLRO & Compliance Officer for Bybit's ADGM-licensed Recognised Investment Exchange (RIE) and Recognised Clearing House (RCH) entities, based in the UAE. This senior role combines Compliance Officer and MLRO functions for market infrastructure operations under the FSRA regime.

Company Overview

Bybit is a leading cryptocurrency exchange and digital financial platform established in 2018, serving over 80 million users across more than 200 countries and regions. The platform delivers a seamless ecosystem across trading, payments, wealth management, custody, institutional services, and Web3. Bybit is recognized as one of the most trusted and transparent platforms in the digital asset industry, supported by a global team and 24/7 multilingual customer service.

Role Purpose

To lead the compliance and financial crime function for ADGM-licensed market infrastructure entities, ensuring adherence to all FSRA Rules, regulatory obligations, and financial crime frameworks while building practical, scalable compliance frameworks that navigate the unique regulatory expectations of exchange and clearing house operators.

Key Responsibilities

Compliance Oversight

• Design, implement, and oversee the compliance function across both RIE and RCH entities.
• Monitor adherence to all FSRA Rules, FSMR, MIR, and applicable regulations governing RIE and RCH operations.
• Develop and maintain compliance policies, procedures, and monitoring programmes specific to exchange and clearing house operations, including market surveillance, rulebook compliance, default management procedures, and participant conduct oversight.
• Conduct regular compliance reviews, testing, and gap analyses across both entities, ensuring controls are proportionate to systemic risk profile.

Governance & Advice

• Provide independent compliance advice to the Board and senior management of both entities.
• Escalate material issues in accordance with governance frameworks.
• Advise on new market products, trading rules, participant admission criteria, and clearing arrangements to ensure ongoing regulatory alignment.

Regulatory Engagement

• Liaise with the FSRA on all compliance matters relating to the RIE and RCH.
• Ensure timely and effective remediation of regulatory findings.
• Act as key point of contact with the FSRA and other relevant authorities on financial crime matters.

Stakeholder Collaboration

• Partner with Legal, Risk, Technology, and Operations teams to embed compliance requirements across both entities' operating models.

AML/CFT/Sanctions Programme

• Hold overall responsibility for the implementation, oversight, and effectiveness of the AML/CFT/sanctions programme across the RIE and RCH in accordance with the FSRA AML Rulebook.
• Receive, investigate, and decide on internal suspicious activity reports (SARs/STRs).
• File reports with relevant authorities including via goAML where applicable.
• Develop and maintain AML policies, risk assessments, CDD, EDD, and ongoing monitoring procedures tailored to the participant and transactional risk profile of a virtual asset exchange and clearing house.
• Maintain and periodically review the entity's Business Risk Assessment (BRA) and Customer Risk Assessment (CRA) frameworks in the context of market infrastructure operations.

Training & Awareness

• Ensure staff training and awareness programmes on AML/CFT are current, documented, and proportionate to the risk environment.

Reporting

• Provide regular AML reporting to the Board.

Qualifications & Experience

• 10+ years of significant senior compliance and/or financial crime experience within ADGM, DIFC, or other regulated financial services environments.
• Preference for market infrastructure, exchange, or clearing experience.
• Strong working knowledge of FSRA Rules, FSMR, MIR, the ADGM AML Rulebook, and applicable sanctions frameworks.
• Understanding of RIE and RCH regulatory obligations, including rulebook governance, participant oversight, default management, and systemic risk considerations.
• Experience supporting regulatory authorisations, recognition applications, or supervised entity setup.
• Experience engaging with the FSRA or equivalent regulator on market infrastructure supervisory matters.
• Prior MLRO, Compliance Officer, or equivalent senior control function experience, ideally within a recognised exchange, clearing house, or market infrastructure operator.
• Exposure to virtual asset market infrastructure, crypto exchanges, or traditional exchange/clearing environments.

Skills & Competencies

• Ability to manage compliance responsibilities across two distinct but related regulated entities within a unified framework.
• Strong judgement, stakeholder management, and decision-making capability.
• Practical, commercially minded approach with ability to manage complexity across dual-entity structures.
• Demonstrated interest in and practical adoption of AI technologies to enhance compliance, regulatory, or operational effectiveness.

Additional Information

• Approved Person status or willingness to seek FSRA regulatory approval for the Compliance Officer and MLRO controlled functions across both entities.
• Study Growth Fund supporting professional development and continuous learning.
• Internal Events including regular team-building activities, workshops, and collaboration opportunities.
• Global Collaboration as part of a diverse, international team.
• Career Advancement opportunities within a rapidly expanding global company.
• Internal Mobility with long-term development support and internal job opportunities.