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We help clients in all sectors, from Funds and Asset Managers to Banking, Financial Institutions and Insurance companies who have to address this concern in order to operate effectively and within the parameters of their legal and regulatory requirements. Arendt provides advice on how to meet your legal obligations within every sector, and implement standards to ensure business integrity, compliance, transparency and security.
Ask your usual contact at Arendt for assistance understanding your unique situation under anti-money laundering and counter terrorist financing measures in Luxembourg and abroad, and to identify the best options from our range of services.
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Our Services
1. KYC, CDD and ongoing monitoring
2. Internal AML / CFT compliance
3. Investment management and AML / CFT documentation
4. Legal and operational assistance with AML / CFT shortcomings
5. External AML / CFT services
6. Key mandates (MLRO, AML Officer, RC, etc.) for investment funds and GPs managing investment funds
7. General legal and operational advice regarding AML / KYC
More about the context (5th AML directive) and AML / CFT-related material
Definitions
Related content and news [NEW CONTENT AVAILABLE - 21/01/2021]
1. KYC, CDD and ongoing monitoring
Arendt Services is a seasoned domiciliation agent, transfer agent and service provider, well equipped to ensure a comprehensive review and sound implementation of your business activities.
Services include execution and operational assistance in:
- CDD and risk classification
- Ongoing monitoring
- AML / KYC onboarding procedures for investors / service providers
- TFS / name screening
Learn more about the business facilitator Arendt Services_
Read about our fund administration and risk management services_
2. Internal AML / CFT compliance
It is essential to internally appropriate AML / CFT matters and to implement targeted methodology capable of ensuring compliance in this area. Draw on specialised knowledge from the AML / CFT team at Arendt & Medernach and Arendt Regulatory & Consulting, as well as Arendt's range of robust operational tools.
Services include drafting and review of:
- AML / CFT checklists
- Internal AML / CFT policies and procedures
- Procedures for asset-side due diligence
- Internal risk assessments, e.g.:
- Establishing a risk-based approach
- Defining a risk assessment framework and methodology
- Review of fund distribution networks
- Country risk assessments
- Establishing a country AML / CFT equivalency assessment
- Description of KRIs for monitoring delegated AML / CFT activities
Find out more about compliance and risk management with Arendt Regulatory & Consulting_
3. Investment management and AML / CFT documentation
Tap into the knowledge of Arendt & Medernach’s Investment Management team to ensure compliance at every stage of fund development.
Services include AML / CFT-focused drafting and review of:
- Prospectuses and other launch documents
- Subscription / application forms and agreements
- Service provider agreements
Arendt's teams can also update and review internal AML / CFT policies and procedures for investment funds and fund managers.
Meet the Fund Formation team and find your path to full compliance_
4. Legal and operational assistance with AML / CFT shortcomings
Sometimes you may find a flaw. When that happens, Arendt is by your side.
- Review of the AML / CFT related sections in the auditors’ reports
- Dialog with the Luxembourg regulator
Get in touch with your usual Arendt contact.
Find out more about compliance and risk management with Arendt Regulatory & Consulting_
5. External AML / CFT services
Build your own AML / CFT skills to ensure your business is compliant. For certain professionals, AML / CFT training and awareness measures are a mandatory part of compliance. Consider a training programme at Arendt Institute offering a training certificate, or get bespoke support from an Arendt KYC expert.
- Provision of secondments with regard to AML / CFT, e.g. as part of KYC support (Investor Onboarding / Remediation Plan)
- External AML / CFT presentations, i.e.:
- AML / CFT workshops and training
- Webinars
- Targeted AML / CFT client meetings / workshops on current legal topics
Train your staff through a comprehensive learning solution by Arendt Institute_
6. Key mandates (MLRO, AML Officer, RC, etc.) for investment funds and GPs managing investment funds
Arendt entities can accept mandates for the roles needed to comply with AML / CFT rules, and can advise persons currently serving in those roles.
- Provision of the RC mandate
- Advice / support to the MLRO / AML Officer / RC
- Drafting and review of documents regarding the appointment of the MLRO / AML Officer / RC:
- AML agent agreements
- Circular resolutions and other corporate forms and documents
- Coordination of the CSSF filing procedure for MLRO / AML Officer / RC appointments
Get in touch with your usual Arendt contact.
More information about our RC/AML-CFT Compliance Officer services_
7. General legal and operational advice regarding AML / KYC
Arendt entities remain by your side to treat the various obligations and requests from authorities that arise throughout the year. For example:
- RBO services
- UBO analysis for clients and updates upon request
- Filing with the RBO and ongoing updates upon request
- AML / CFT country assessments
- Regulatory questionnaires and reports
- Assistance completing annual CSSF AML / CFT questionnaires
- Assistance completing CSSF AML / CFT market-entry questionnaires (funds or IFMs)
- Liaising with Luxembourg’s Financial Intelligence Unit (FIU)
- Assistance with entity registration in goAML (FIU suspicious transaction reporting tool)
- Legal assistance filing SARs and STRs
Get in touch with your usual Arendt contact.
Our teams of experts
Go through your usual contact at Arendt to ensure your request reaches the right team, whether you are based in Luxembourg or elsewhere in the world.
Definitions
AML: anti-money laundering
CDD: customer due diligence
CFT: combating the financing of terrorism; CTF: counter terrorist financing
FIU: Luxembourg Financial Intelligence Unit
GP: general partner
IFM: investment fund manager
KRI: key risk indicator
KYC: know your customer
MLRO: money laundering reporting officer; RC: responsable de contrôle
RBO: Register of Beneficial Owners; RBE: registre des bénéficiaires effectifs
SAR: suspicious activity report
STR: suspicious transaction report
TFS: targeted financial sanctions
UBO: ultimate beneficial owner
Related content
Newsflashes
19/01/23 - Register of Beneficial Owners: Access restored for professionals, subject to conditions
24/11/22 - AML V & register of beneficial owners: a public access feature found to be invalid by the CJEU
05/08/22 - Fight against money laundering and terrorist financing – List of primary offences extended
16/06/22 - AED's AML guidelines for RAIFs
26/07/21 - The new EU AML-CFT package
21/01/20 - Anti-money laundering and counter terrorist financing – mandatory survey due in March 2021
11/09/20 - New AML / CFT CSSF Regulation and Grand-Ducal Regulation
11/09/20 - New CAA AML / CFT regulation
31/03/20 - Law of 25 March 2020 establishing a central data retrieval system for bank, payment accounts and safe-deposit boxes
30/03/20 - Implementation of the 5th AML Directive into Luxembourg law: the last piece of the puzzle – Key aspects and changes of the law of 25 March 2020
22/11/18 - The Luxembourg registers of beneficial owners (“BOs”) expected soon, so get ready!
22/06/18 - 5th AML Directive - Key aspects
06/06/18 - The fifth anti-money laundering and terrorist financing directive (AML 5) - Key aspects and changes
Press/media/publications
12/11/20 - French only - Obligations AML, qui n’est pas concerné?
30/01/20 - French only - Lutte contre le blanchiment d’argent et le financement du terrorisme – Quand le risque pénal du banquier cède le pas face au risque administratif - (01/2020) Glenn Meyer and Helena Finn (AML)
Webinar Recordings
24/02/21 - All you need to know about the recent evolutions to the AML-CTF framework in the insurance sector