Deputy MLRO | Crypto Assets and Payments
Reporting to: Chief Compliance Officer & Money Laundering Reporting Officer
Function: Compliance & Financial Crime Prevention
Eligibility: Open to all genders
About LDC EU
LianLian LDC Finternet EU GmbH is developing stablecoin-based payment infrastructure connecting digital assets with international financial services. Our European business combines crypto-asset services and payment activities, with a strong emphasis on effective governance, financial crime prevention and regulatory compliance. We are seeking an experienced Deputy Money Laundering Reporting Officer to help establish, implement and maintain an effective AML/CFT framework for our Austrian entity. The position offers substantial responsibility in shaping the controls, systems and operational standards supporting LDC EU’s authorisation readiness and subsequent operations.
The role
Reporting directly to the Chief Compliance Officer & MLRO, you will support the oversight and practical implementation of LDC EU’s anti-money laundering and counter-terrorist financing framework, with the Austrian Finanzmarkt-Geldwäschegesetz (FM-GwG) as its principal legal foundation.
This is a senior specialist position requiring independent judgement, strong investigative capabilities and a practical understanding of crypto-assets, stablecoins, blockchain transactions and payment flows. You will translate regulatory requirements into effective procedures, system controls and documented decisions, working closely with Operations, Product, Technology, Legal and Risk.
As the appointed Deputy MLRO, you will deputise for the MLRO during their absence and undertake delegated responsibilities within a clearly documented mandate. You must be capable of maintaining continuity of the function, making timely decisions within your authority and escalating material concerns directly to the appropriate management level. The position forms part of the independent Compliance function and requires constructive challenge of business decisions and operational practices.
Languages
- Professional fluency in English, including the ability to draft formal documentation and communicate complex regulatory matters clearly.
- German business-fluent level is preferred, particularly for interpreting Austrian legislation, preparing regulatory correspondence and engaging with Austrian authorities.
Key responsibilities
- AML/CFT framework and regulatory implementation. Support the design, implementation and ongoing maintenance of policies, procedures and controls under the FM-GwG, applicable FMA requirements and relevant European guidance. Ensure that the framework appropriately addresses LDC EU’s crypto-asset and payment activities, including relevant interfaces with MiCAR, the Austrian Zahlungsdienstegesetz 2018 (ZaDiG 2018) and Regulation (EU) 2023/1113 on transfers of funds and certain crypto-assets.
- Risk assessment. Maintain and enhance the company-wide AML/CFT risk assessment and customer risk assessment methodology. Evaluate risks arising from customers, beneficial owners, jurisdictions, products, transaction patterns, distribution channels and new technologies, including stablecoin payments and transfers involving self-hosted addresses.
- Customer due diligence. Oversee and challenge customer onboarding, identification and verification, beneficial ownership analysis, ongoing monitoring and periodic reviews. Assess complex corporate structures, politically exposed persons, higher-risk relationships, and source-of-funds and source-of-wealth evidence. Make or recommend onboarding, restriction and exit decisions within the approved authority framework.
- Transaction monitoring and investigations. Oversee the effectiveness of fiat and crypto-asset monitoring controls and lead complex or escalated investigations. Combine customer information, payment records and blockchain analytics to assess unusual activity, substantiate findings and document defensible decisions. Review monitoring scenarios, thresholds, alert quality and remediation needs.
- Suspicious activity reporting. Assess potential reporting obligations, prepare clear and substantiated suspicious transaction/activity reports, and submit reports to the Austrian Financial Intelligence Unit through goAML where authorised. Maintain complete investigation records, observe confidentiality and tipping-off restrictions, and support timely responses to competent authorities.
- Travel Rule compliance. Support the implementation and oversight of originator and beneficiary information requirements, counterparty CASP assessments, missing or incomplete information handling, and controls for transfers involving self-hosted addresses. Ensure that exceptions, transfer decisions and supporting evidence are appropriately recorded.
- Sanctions and related financial crime controls. Work closely with the designated Sanctions Officer on customer, beneficial-owner, counterparty and wallet screening, sanctions escalations and potential circumvention indicators. Support the application of EU and Austrian financial sanctions requirements, including relevant FM-GwG provisions and the Sanktionengesetz 2024, within the agreed allocation of responsibilities.
Professional experience and regulatory knowledge
- Substantial relevant experience in AML/CFT, financial crime compliance or investigations within regulated financial services. Five or more years of relevant experience is preferred.
- Demonstrable practical experience with crypto-assets or digital-asset financial services, ideally involving stablecoins, crypto-asset transfers, custody arrangements or cross-border payments.
- Strong working knowledge of the Austrian FM-GwG and the ability to apply its requirements to operational decisions, customer cases and control design. Direct experience with Austrian FMA supervisory expectations is highly advantageous.
- Sound understanding of the EU Travel Rule and the relationship between AML/CFT obligations, MiCAR and payment services regulation.
- Experience handling complex due diligence, transaction monitoring investigations, suspicious activity reporting and documented escalation decisions.
Strong analytical and drafting skills, with the ability to produce clear policies, investigation conclusions, management reports and regulatory responses.Confidence to exercise independent judgement, challenge senior stakeholders and escalating concerns promptly while working constructively across an international organization, with demonstrated technical and crypto expertise.
Candidates should be able to demonstrate:
- A practical understanding of blockchain transactions, wallet addresses, transaction hashes, token transfers, custodial and self-hosted wallets, and the relationship between on-chain activity and internal customer records.
- The ability to trace and interpret crypto-asset flows using blockchain explorers and analytics tools, while recognising limitations in address attribution, risk scoring and transaction visibility.
- Understanding of relevant financial crime typologies, including obfuscation, chain-hopping, bridges, mixers, fraud proceeds and sanctions evasion.
- Familiarity with digital onboarding, sanctions screening, transaction monitoring, Travel Rule and case-management platforms.
- Sufficient technical literacy to discuss APIs, data flows, automated decision rules, access permissions and audit logs with Product and Technology teams, and to assess whether implemented controls satisfy compliance requirements.
Additional advantages
- Previous appointment as a Deputy MLRO, MLRO or comparable senior financial crime specialist.
- Experience supporting an Austrian or European authorisation process, supervisory inspection or regulatory remediation programme.
- Practical familiarity with goAML and Austrian suspicious activity reporting.
- Experience with platforms such as Elliptic, Sumsub, LSEG World-Check or comparable solutions.
- Relevant qualifications such as CAMS, ICA certifications, specialist Austrian AML training or blockchain investigation certifications.
- A degree in law, finance, economics, business, information systems or a related discipline, or equivalent relevant professional experience.
- Data analysis capabilities, including advanced Excel, SQL or comparable tools.
The opportunity
This position provides the opportunity to shape the AML/CFT function of a crypto-focused payments business, work directly with the CCO & MLRO, and influence how regulatory requirements are embedded into products, technology and daily operations.
We welcome candidates who combine regulatory depth with practical execution, take ownership of complex issues and maintain high standards of integrity, documentation and professional judgement.
Equal Opportunity Statement
We are an equal opportunity employer. We celebrate diversity and are committed to creating an inclusive environment for all employees. All qualified applicants will receive consideration for employment.