Our specialist entities have been mobilised to help clients address this concern in every phase of development, through every type of transaction. Arendt provides advice on how to meet the flood of related legal obligations, and how to implement standards to ensure business integrity, compliance, transparency and security.

Ask your usual contact at Arendt for details regarding your AML/CFT situation, and to identify the best options for you from our range of services.

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

Meet our teams of experts

More about the context (5th AML directive) and AML/CFT-related material

Definitions
Related content and news

 

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. Benefit from the in-depth knowledge of Arendt & Medernach’s KYC team, and the robust operational tools offered by Arendt Regulatory & Consulting.

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

Meet Arendt & Medernach’s Risk and Compliance team_
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

In addition, Arendt & Medernach’s Investment Management team offers also to update and review a fund´s or investment fund manager´s internal AML/CFT policies and procedures.

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.

 

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 make sure that your request reaches the appropriate team.

 

Definitions


AML: anti-money laundering
CDD: customer due diligence
CFT: 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

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

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

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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
The law1 of 25 March 2020 implementing EU Directive 2018/8432  (the “5th AML Directive”) and amending the law of 12 November 2004 on the fight against...
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5th AML Directive - Key aspects
The 5th AML Directive was published in the Official Journal of the European Union on 19 June 2018, and will enter into force 20 days thereafter.
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The fifth anti-money laundering and terrorist financing directive (AML 5) - Key aspects and changes
New directive on the prevention of the use of the financial system for the purposes of money laundering or terrorism financing
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