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

Recognising the increasing complexities faced by Luxembourg Professionals, The AML Office was established to provide independent assurance to Luxembourg Professionals that their AML/CFT legal obligations are being efficiently met, thereby avoiding client, shareholder, financial or reputational detriment.
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Integrity is our core value. Every decision we make and action we take is guided by this core principle. ‘Doing the right thing for the right reason’.
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The AML office

miriem belkacem

Managing Partner

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David Whelan

Partner

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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.

Independent

Protect

adaptive

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.

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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.

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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.

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AML Compliance Reviews

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

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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.

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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

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uSEFUL LINKS

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CONTACT
  • address
  • 56, Rue Charles Martel
  • L-2134
  • Luxembourg

Disclaimer

Aim of the website

The aim of www.TheAMLOffice.com (the “Website”) is to present The AML Office. It is intended solely to provide information about the business of The AML Office.
The AML Office has taken all reasonable care to ensure the correctness and accuracy of information published on the website, at the time of online publication. However, The AML Office cannot make any representation or warranty of any nature, expressly or implicitly, about the completeness, accuracy, reliability, suitability or availability of the services and products described on the website. You should not rely solely on the information contained on the website. In particular, The AML Office cannot be made liable for any direct or indirect damage resulting from the information provided on the website.

No offer, no solicitation

The website is for information purposes only. Nothing contained therein constitutes or shall be deemed to constitute a financial, legal, tax or other advice of any kind and no information on the website shall constitute or deem to constitute a solicitation or an offer to purchase, or invest in, any financial products which are referred to on the website.

Data protection

Via the website you are able to find detail about our company and our services and can contact us. By doing so you agree to the processing of any personal data that you provided to us, which may include your name, e-mail address, telephone number, age, gender, professional qualifications as well as any other personal data provided to us.

The AML Office will take all reasonable care to ensure that your personal data is held confidentially and used only for the processing of your request and for marketing purposes (such as distribution of our Newsletter and invitations to client events) in accordance with the General Data Protection Regulation (“GDPR”). Please note that as your personal Data is hosted on a third party server located in Luxembourg, the personal Data you provided via our website will also be hosted on a third party server.

The AML Office will take adequate measures to ensure that your personal Data is not transferred to any third party outside its group, unless otherwise required by Luxembourg law.

Under GDPR, you have the right to access and rectify your personal data. Should you wish to do so, please contact us via email

Liability disclaimer

Any information on the website does not constitute a legal, tax, accounting or any other professional advice or service. The AML Office accepts no liability for any loss arising as a result of any action taken or refrained from as a result of information contained on this site or any other sites to which this site may be linked.

Copyright

Any reproduction or representation, in whole or in part, of these pages, data and any other element making up the site, by whatever process or tool, is forbidden and subject to the express permission of The AML Office. Failure to do so shall be considered as an infringement of copyright.

Confirmation

By visiting the website, downloading information and/or requesting for information, you specifically acknowledge that certain data may be traced. Inter alia, and without limitation, The AML Office may use cookies to facilitate your future visits, track your usage, or to analyse the number and location of visitors on the website. Any data stored, including IP address, is used for administrative purposes only and is strictly confidential. In this context, you are specifically reminded that the use of the Internet does not constitute a safe means of communication or exchange of information. Consequently, you specifically recognise that you use this network at your own risk. The AML Office will, in no circumstances, be directly or indirectly liable for any loss or damage, including without limitation, indirect or consequential loss of damage, of whatever nature arising from loss of data or profits arising from the use of the website.

Additionally, the website may contain links to other websites owned and/or operated by entities other than The AML Office. These websites are out of the control of The AML Office and we neither endorse nor warrant any representation as to the content, nature and availability of such websites. Such links do not constitute a recommendation of any nature.

The AML Office and its affiliates hold a professional indemnity insurance against liability arising from professional negligence which is appropriate to the risks covered.

If you do not agree with the Terms of Use, you must stop using the website.

Governing Law and Jurisdiction

This Term of Use shall be construed in accordance with, and governed by the laws of the Grand Duchy of Luxembourg. Any litigation or dispute arising out of the Terms of Use is submitted to the exclusive jurisdiction of the courts of Luxembourg.

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