Independent anti-money laundering specialists
- Safeguarding reputations
The AML
Office
is an
independent consultancy
firm
specialising in regulatory affairs for the Luxembourg Investment Funds industry
We believe the complexity of anti-money laundering and countering the financing of terrorism (AML/CFT) laws and regulations warrants a comprehensive compliance framework for Professionals across the Investment Funds (IFs) industry. A structure that adequately addresses the specific needs of the entity and protects investors while mitigating risk for management bodies.
our story
our Values
our people
miriem belkacem
Managing Partner
The role of The AML Office is to safeguard reputations
We do this by remaining independent, serving as your second line of defence and continually adapting and protecting you by mitigating your AML/CFT regulatory risk.
Addressing your needs
Luxembourg Professionals are legally obliged to appoint both a “Responsable du respect des obligations (RR)” and a “Responsable du contrôle du respect des obligations (RC)” to oversee compliance with AML/CFT legal requirements.
HOWEVER, FULFILLING THESE ROLES REQUIRES
- Extensive AML legislative knowledge
- Comprehensive business knowledge
- Access to specific documents
- The continual monitoring of activities
- The capacity to evolve compliance processes accordingly
- Must be contactable by the Luxembourg competent authorities
The RR is responsible for AML compliance.
The RC is the day-to-day contact for escalation of AML/CFT related matters.
OUR FULLY-INTEGRATED SERVICES
The AML Office team is comprised of AML/CFT experts, KYC remediation specialists, experienced Conducting Officers and Investment Fund Directors.
Provision of Non-Executive Director (RR Services)
Offering experienced fund industry professionals as an independent director to Irish and Luxembourg domiciled funds including the expertise and experience to act as RR/RC for the management body should it be required.
Provision of MLRO/AMLCO (RC Services)
Provision of a comprehensive and robust AML/CFT compliance framework duly implemented to ensure ongoing compliance with the Luxembourg AML/CFT legal obligations.
Conducting an in-depth gap analysis of your AML/CFT legal obligations against existing policies and procedures, presenting recommendations and assisting with the necessary remediation as necessary.
AML Consultancy/Advisory
Consult with us on your various AML needs and our experts will strive to find workable cost-effective solutions.
AML Training
Provision of bespoke AML/CFT training programmes including annual AML training for members of Investment Fund management bodies.
Provision of Conducting Officer to Luxembourg Management Companies
Offering experienced Conducting Officers, with a specific focus on compliance and operational risk management functions.
Regulatory Compliance framework development and support
Whether it is the creation, review or enhancement of your existing regulatory compliance framework, talk with our specialist advisors about what we can do for your entity.
Consultancy and training on fund specific regulatory obligations
Provision of bespoke training programmes on various fund-specific topics.
Our approach
to
good governance
The AML Office offers a systematic, targeted and disciplined approach to providing specialist governance and compliance-related services to support Luxembourg Investment Funds and Investment Fund Managers meet their AML/CFT legal and regulatory obligations. We do this by establishing and coordinating a regulatory compliance oversight framework.
Luxembourg Laws & Regulations, CSSF Circulars, Industry Best Practice
- Develop AML Legal Obligations Register
- Include responsibility allocations
AML Compliance framework & detailed AML risk assessment
- Develop & maintain AML Policies and Procedures
- Draft AML Risk Assessment (inherent and Residual Risks)
AML Compliance Monitoring programme
- Fund-specific compliance monitoring programme developed
- Ensuring completeness of meeting AML obligations
- Status updates form the basis of Quarterly Board Reports
- Assessing the service providers' operations annually
Full audit trail with documentary evidence securely stored
- All documentary support to prove on-going compliance with the AML Obligations is retained in a secure cloud storage facility
- Ease of access to authorised partiess
Dashboard of AML Obligations and current status
- Traffic light graphics on Key Performance and Key Risk Indicators
- AML Obligations status observable at any point in time
- Quarterly/Annual AML Reports
insights
New AML/CFT measures for unregulated Luxembourg Alternative Investment Funds
Tight filing deadline of the AED 2021 AML/CFT Questionnaire for unregulated investment funds in Luxembourg. On 12 October 2022, the Administration de l’enregistrement, des domaines et de la TVA (“AED”) published an update on their website to enhance the visibility of key AML/CFT measures being put in place for
CSSF – AML/CFT central repository
Within the framework of its statutory mission, the CSSF is in charge of ensuring that all the persons subject to its supervision, authorisation or registration comply with the professional AML/CTF obligations.
CSSF publishes updated Collective Investment Sub-Sector Risk Assessment (CI SSRA)
The CSSF recently published an update to the 2020 CI SSRA setting out the inherent risk for the Collective Investment Sector remains high as detailed in the National Risk Assessment (NRA) updated in 2020. The present assessment focuses on the evolutions to highlight several ML/TF threats and vulnerabilities that