Audit & Assurance Services

Challenge: A leading Alternative Investment Management Company faced the challenge of deploying an AML/CFT governance framework that would remain aligned with the financial targets while ensuring effective compliance with relevant legislative requirements in Luxembourg.

Solution: PwC Luxembourg has deployed a dedicated team of AML Subject Matter Experts, providing year-round support to the RC of the Funds managed by the AIFM, involving the review, development and execution of the full set of regulatory required policies, procedures and controls, across the Funds, their  investors, assets and delegates. The RC of the AIFM directs the PwC team and maintains controls. 

Benefits: The AIFM effectively benefitted from the structured and comprehensive AML/CFT framework deployed across the whole population of Luxembourg Funds, increased coherency in the procedural and operational dimensions, significant decrease in the control’s execution timing through the integration of the digital solutions as well as an exhaustive reporting setup, tailored to the specific responsibilities and needs of the stakeholders. 

Challenge: A major life insurance provider faced significant relationship challenges with brokers across various markets due to the complexity and volume of AML documentation requests. The frequent, detailed documentation demands required for AML compliance had placed strain on broker interactions, affecting their ability to maintain positive client relationships and sometimes even resulting in client redirection to competing products. The strain impacted brokers at the forefront and left clients feeling dissatisfied with the service.

Solution: PwC Luxembourg conducted a diagnostic study involving in-depth interviews with the insurer’s most impacted partners. Our team listened to and gathered feedback from brokers to understand specific issues they encountered with documentation requirements. This feedback enabled us to pinpoint “pain points” and areas for improvement. We then performed a detailed analysis to assess the necessity and relevance of each requirement, balancing compliance needs with broker relationships. The project culminated in a tailored action plan, complete with a quadrant-based approach prioritising actions by impact and effort.

Benefits: The insurer achieved a refined, streamlined AML documentation process, reducing friction in broker interactions while maintaining compliance standards. This approach improved broker relationships and enabled smoother client interactions. By alleviating operational burdens, the insurer safeguarded its business partnerships and enhanced customer satisfaction, supporting sustainable commercial growth.

Challenge: A life insurance company sought to implement a third-party introduction process (TPIP) to meet the stringent AML/CFT requirements under Luxembourg law and regulations. Positioned at the initial phase of discussions with the regulatory authority (CAA), the client required an assurance that its framework would meet the necessary legal standards. The insurer, with a TPIP model already in place in another entity of the same group, needed PwC Luxembourg’s expertise to align its process with local compliance expectations.

Solution: PwC Luxembourg conducted a comprehensive gap analysis of the client’s planned TPIP framework to verify alignment with regulatory requirements. We assessed all areas of the framework for regulatory compliance, identifying gaps and offering targeted recommendations where enhancements were needed. Additionally, we provided support in identifying the necessary content of a third-party introduction agreement to ensure the scope and terms complied with Luxembourg’s regulatory environment.

Benefits: By receiving a pre-emptive assessment and alignment of its TPIP framework, the insurer gained confidence in its future regulatory submission and minimised potential compliance risks. This collaboration also clarified the regulator's expectations and enhanced the insurer's readiness for implementation, supporting long-term AML/CFT compliance while promoting operational consistency across group entities.

Challenges: Our client, a large hotel chain operating in southern Europe, is due to come in scope of CSRD in FY2025. They needed to align their reporting with CSRD, starting with their Double Materiality Assessment. They also needed to identify and understand the existing data gaps between their reporting and the CSRD requirements.  

Solution: PwC reviewed the client’s Double Materiality Assessment and its alignment with ESRS, using an audit-ready approach to challenge both the procedures and results. Through an iterative process, the assessment is enhanced annually, ensuring it is comprehensive and compliant by the time the CSRD applies to the company. 

Benefits: The client benefited from a limitation of the risks associated with the application of CSRD, and a streamlined reporting processes, aligned with the CSRD requirements.