Role Title

Anti-Money Laundering & Reporting Officer (AMLRO), Cyclops EEC Services, GmbH

Role Overview

We are seeking an experienced and credible Anti-Money Laundering & Reporting Officer (AMLRO) to serve as the designated AML/CFT responsible person for Cyclops EEC Services GmbH under Austrian law and applicable EU regulation. This role is critical to our MiCA licensing process and to our long-term regulatory standing with the FMA and other relevant authorities.

This is a rare ground-floor opportunity to shape the compliance DNA of a well-capitalized, high-growth company at a pivotal moment. You won't be inheriting someone else's program. You'll be building it.

This is a high-ownership role at a fast-moving startup. In the first phase lasting approximately six months, you will operate as a senior individual contributor — working closely with external legal advisors, fractional compliance specialists, and the Austrian entity MD and US parent leadership team to build our AML/sanctions framework from the ground up. Following license approval, you will enter a team-building phase, hiring and leading a dedicated compliance function, ensuring that the AML/CTF controls are properly implemented and effective.

The AMLRO will report directly to the Managing Director of Cyclops EEC Services GmbH, with a strong dotted line to parent company executive leadership in the US.

The AMLRO needs to be based in Austria, and fluency in English and German is a must.

Our ideal candidate has previously passed the Fit & Proper assessment of the FMA.

Key Responsibilities 

Regulatory & Licensing (Immediate Priority)

• Serve as the named AMLRO for the FMA MiCA licensing application and act as the primary point of contact for FMA on all AML/CFT matters
• Lead the design and implementation of a comprehensive AML/CFT and sanctions compliance program tailored to the Austrian regulatory framework and MiCA requirements
• Draft, own, and maintain all core AML/sanctions policies, procedures, risk assessments, and internal controls documentation
• Coordinate with external Austrian legal counsel, advisors, and auditors to ensure timely and complete regulatory submissions
• Represent the company in regulatory meetings, audits, and examinations with the FMA and other competent authorities

Program & Policy Development

• Build the company's AML/CFT risk appetite framework and Business-Wide Risk Assessment (BWRA)
• Develop Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Know Your Customer (KYC) policies appropriate for a payments and crypto-asset environment
• Establish transaction monitoring frameworks, suspicious activity detection typologies, and Suspicious Activity Report (SAR/VerdachtsmeldungMeldung) processes in line with Austrian FM-GwG and EU AMLD requirements
• Design and implement a sanctions screening program covering OFAC, EU, UN, and Austrian/FMA-specific sanctions regimes
• Develop an AML training program for staff across the Austrian entity and relevant US parent personnel

Implementation and Oversight of AML/CFT Compliance Programme

• Ensure that AML/CFT policies, procedures and internal controls are properly implemented and effective.
• Oversee day-to-day compliance with the FM-GwG risk-based obligations, including customer due diligence (CDD), enhanced due diligence (EDD), transaction monitoring, escalations, SAR filing, and sanctions/PEP screening
• Manage and provide direction to external advisors and fractional compliance resources
• Prepare and present regular compliance reporting to the Managing Director and Board
• Ensure that potentially suspicious transactions are escalated and the relevant suspicious activity reports (SARs) are filed with the Austrian FIU (Bundeskriminalamt) in accordance with legal timeframes
• Stay current on evolving EU AML regulations (including the forthcoming EU AML Authority — AMLA), MiCA implementation guidance, and FMA supervisory expectations

Team Building

• Develop a staffing plan for the compliance function to support the company's post-license growth
• Recruit, onboard, and lead a team of AML analysts and compliance specialists
• Build scalable compliance infrastructure, leveraging technology and RegTech solutions appropriate for a payments and digital asset business

Qualifications

Required Qualifications

• 6+ years of AML/CFT compliance experience, with meaningful exposure to payments, fintech, or crypto/digital asset environments
• Demonstrated experience as a named AMLRO, Compliance Officer, or equivalent regulated function holder with a European financial regulator — FMA experience is a strong plus
• Required professional competence and personal reputation and integrity to meet the “Fit & Proper” requirements, ideally already passed the “Fit & Proper” assessment
• Deep knowledge of Austrian AML law (FM-GwG, BWG, MiCA-VVG etc), EU Anti-Money Laundering Directives (AMLD4/5/6) – MiCA regulatory experience is a strong plus
• Hands-on experience building or significantly overhauling AML policies, risk assessments, and compliance programs — not just following orders within established frameworks
• Familiarity with crypto-asset-specific AML typologies, Travel Rule compliance (FATF Recommendation 16), and blockchain analytics tools (e.g., Chainalysis, Elliptic, or equivalent)
• Experience managing external counsel, auditors, and third-party compliance vendors
• Fluency in both English and German (written and spoken) 
• Strong professional credibility and the interpersonal presence to represent the company confidently before regulators

Preferred Qualifications

• Prior experience supporting a MiCA, E-Money Institution (EMI), or Payment Institution (PI) license application in Austria or another EU jurisdiction
• CAMS (Certified Anti-Money Laundering Specialist), ICA, or equivalent professional certification
• Experience working within or alongside a US-headquartered parent company, with an understanding of cross-border compliance governance
• Experience selecting and implementing RegTech, transaction monitoring, or KYC/onboarding platforms

Why This Role

• Build something that matters: You will have genuine ownership over the compliance framework of a new, well-funded entity — a blank canvas, not a bureaucratic inheritance
• Regulatory visibility: You will be a named officer with direct FMA relationships and a seat at the leadership table
• Growth trajectory: This role evolves from senior IC to compliance team lead as the business scales post-license
• Well-resourced: Cyclops is well-funded and committed to investing properly in compliance — you will have the budget, tools, and external support to do the job right
• Competitive compensation: Salary and benefits commensurate with senior regulatory function experience in the Austrian market

Location

Vienna, Austria. On-site presence is preferred, particularly during the FMA licensing phase, as regulatory credibility and availability to the FMA are important considerations for this role. Hybrid arrangements may be available following license approval. Austrian residency or a firm commitment to relocate to Austria is required.

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About Cyclops

Cyclops is the only crypto and stablecoin infrastructure provider exclusively focused on payments. Historically, crypto and stablecoin payments have been unnecessarily difficult. With Cyclops, the era of delays and complexity is over.

We are serial entrepreneurs. We founded The Giving Block in 2018, sold it to Shift4 (NYSE: FOUR) in 2022, then spent the last 4 years building out the Shift4 crypto team and products. Now, we’re running things back and following a similar playbook. This time we’re more prepared and backed by the best in the industry (Castle Island, Fidelity, and Shift4).

Cyclops Culture

Don’t join Cyclops if you’re looking for a typical 9-5. The culture we’ve built is one of first-principles thinking and relentless execution. We wake up every day excited to deliver great products worthy of the world’s best companies. Everyone who works at Cyclops must have a founder mindset, where no problem is too big to solve.