Role Title

Anti-Money Laundering Reporting Officer (AMLRO) and Sanctions Officer

Company Description

Crypto and stablecoins will transform payments infrastructure. We are unifying the components that unlock that potential. Cyclops is the first infrastructure company solely dedicated to empowering payments companies to offer crypto and stablecoin solutions.

Cyclops EEC Services GmbH is our wholly owned Austrian entity, established to, after successful licensing, serve European markets and currently pursuing MiCAR and PSD2 Lite licenses with the Austrian FMA (Finanzmarktaufsicht). 

We are seeking an experienced and credible Anti-Money Laundering & Reporting Officer (AMLRO) and Sanctions Officer to serve as the designated AML/CFT and sanctions responsible person for Cyclops EEC Services GmbH under Austrian law (especially the FM-GwG) and applicable EU regulation. This role is critical to our MiCAR licensing process and relationship with the 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 Managing Director and US parent leadership team to build our AML/CTF and 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 and sanctions controls are properly implemented and effective.

The AMLRO and Sanctions Officer will report directly to the Managing Director of Cyclops EEC Services GmbH.

The AMLROand Sanctions Officer 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 AMLROand Sanctions Officer for the FMA MiCAR licensing application and act as the primary point of contact for FMA on all AML/CFT and sanctions matters
• Lead the design and implementation of a comprehensive AML/CFT and sanctions compliance program tailored to the Austrian and European regulatory framework and MiCAR requirements
• Draft, own, and maintain all core AML/CTF and 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 and sanctions risk appetite framework and Business-Wide Risk Assessment (BWRA)
• Develop AML/CFT and sanctions policies and procedures, specific to the company's business activity, for a payments and crypto-asset environment
• Establish transaction monitoring frameworks, suspicious activity detection typologies, and Suspicious Activity Report (SAR/Verdachtsmeldung) processes in line with Austrian FM-GwG and EU AMLD requirements
• Design and implement a sanctions internal control system in line with the FM-GwG and EU laws, covering  EU, UN, Austrian/FMA-specific and OFAC sanctions regimes
• Develop an AML/CTF and sanctions training program for staff across the Austrian entity and relevant US parent personnel

Implementation and Oversight of AML/CFT and Sanctions Compliance Programme

• Ensure that AML/CFT, KYC and sanctions 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, and support in creating operational structures, procedures and checks ensuring compliance
• Manage and provide direction to external advisors and fractional compliance resources
• Prepare and present regular compliance reporting to the Board
• Undertake regular, periodic and ad-hoc reporting to internal and external stakeholders (e.g. regulators etc.)
• Ensure that potentially suspicious transactions are escalated and the relevant suspicious activity reports (SARs) are filed with the Austrian FIU (Geldwäschemeldestelle) in accordance with legal timeframes
• Submit travel rule reports and sanctions reporting to the FMA in accordance with legal timeframes
• Stay current on evolving EU AML/CTF and sanctions regulations (including the forthcoming EU AML Authority — AMLA), MiCAR implementation guidance, and FMA supervisory expectations
• Collaborate with internal teams, including compliance, finance and operations, to address compliance issues and support business objectives.

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/CTF and sanctions analysts and compliance specialists
• Build scalable compliance infrastructure, leveraging technology and RegTech solutions appropriate for a payments and digital asset business

Qualifications

Required Qualifications

• University Degree in Law, Economics, Finance, Forensics or a related field, with preference for candidates with legal background
• 6+ years of AML/CFT compliance experience, with meaningful exposure to financial institutions, 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 (esp. FM-GwG, SanktG, MiCAR, MiCA-VVG etc), EU Anti-Money Laundering Directives (AMLD4/5/6) – MiCAR regulatory experience is a strong plus
• Hands-on experience building or significantly overhauling AML/CTF and sanctions 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, EU Travel Rule), and blockchain analytics tools (e.g., Chainalysis, Elliptic, or equivalent)
• Good understanding of blockchain technology, digital assets, and the regulatory landscape surrounding crypto-assets. 
• 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 interacting with Austrian regulators, including FMA & Austrian FIU 
• 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 individual contributor 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, state-of-the-art tools, and external support to do the job right
• Competitive compensation: Salary and benefits commensurate with senior regulatory function experience in the Austrian market. Starting gross annual salary of at least € 62,778.38 - depending on qualifications and professional experience, it may be higher.

Location

Vienna, Austria. On-site presence is required, preferably already during the FMA licensing phase, as regulatory credibility and availability to the FMA are important considerations for this role. 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.