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

Role Overview

MLRO & Compliance Officer, UAE (ADGM) at Bybit. This is a senior position leading the compliance and financial crime function for ADGM-licensed Recognised Investment Exchange (RIE) and Recognised Clearing House (RCH) entities, combining both Compliance Officer and MLRO responsibilities across market infrastructure operations.

Company Overview

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. The company 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, powered by world-class technology, a user-first mindset, 24/7 multilingual customer service, and a commitment to innovation.

Role Purpose

Lead the design, implementation, and oversight of compliance and financial crime frameworks for dual ADGM market infrastructure entities. Establish practical, scalable compliance controls that navigate unique regulatory expectations for exchange and clearing house operations while managing systemic risk and regulatory relationships with the FSRA.

Key Responsibilities

Compliance Framework & Governance

• Design, implement, and oversee the compliance function and 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 the RIE and RCH, ensuring controls are proportionate to the systemic risk profile of market infrastructure.
• Advise on new market products, trading rules, participant admission criteria, and clearing arrangements to ensure ongoing regulatory alignment.

Board & Senior Management Engagement

• Provide independent compliance advice to the Board and senior management of both entities.
• Escalate material issues in accordance with governance frameworks.
• Provide regular AML reporting to the Board.

Regulatory Liaison & Remediation

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

Cross-Functional Collaboration

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

AML/CFT Programme Management

• 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.
• 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.

Suspicious Activity & Reporting

• Receive, investigate, and decide on internal suspicious activity reports (SARs/STRs).
• File reports with relevant authorities including via goAML where applicable.

Training & Awareness

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

Qualifications & Experience

• 10+ years of significant senior compliance and/or financial crime experience within ADGM, DIFC, or other regulated financial services environments, with 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.
• Strong UAE/ADGM regulatory credibility, with 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 operator with the 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: participation in regular team-building activities, workshops, and events designed to promote collaboration and innovation.
• Global Collaboration as part of a diverse, international team.
• Career Advancement opportunities for growth within a rapidly expanding global company.
• Internal Mobility offering internal job opportunities to build your career path.