Adequate internal AML / CTF framework
- Design or review your AML / CTF policies and procedures;
- Write or review your AML / CTF risk assessment;
- Assess your vulnerability and enhance your risk management / oversight mechanism;
- Review the internal framework of AML / CTF roles and responsibilities and related controls;
- Design or review the monitoring activities performed by your Compliance Officer / Money Laundering Reporting Officer;
- Provide your Compliance Officer with constant on-demand support;
- Review your Management Information System to improve efficiency of decision making;
- Effectively manage incidents that may create a regulatory or reputational risk.
Working with third parties
- Compare target countries' legislation to Luxembourg key AML / CTF legislation and understand gaps and similarities;
- Conduct specific AML / CTF counterparty due diligence in non AML / CTF Luxembourg equivalent countries;
- Compare the counterparty's AML / CTF policies and procedures to Luxembourg legal requirements;
- Provide ongoing due diligence on your active counterparties in non AML / CTF Luxembourg equivalent countries.
Customer / investor due diligence
- Provide on-demand compliance support to help you understand and assess specific complex cases;
- Support you with setting up and executing customers / investors' re-identification plans (including FATCA-relevant aspects);
- Advise you on setting up a risk assessment and related risk-based approach for your customers / investors;
- Review investor files in the context of fundmigrations;
- Perform background checks on individuals and companies;
- Provide assistance to your customer acceptance committees.
Transaction and sanction monitoring
- Support the selection and implementation of an AML / CTF transaction monitoring, sanction / "blacklist" and PEP screening monitoring tool;
- Define pragmatic behavioural transaction-monitoring tools and reports, based on your customer / investor base and your specific business activity;
- Optimise and validate the monitoring thresholds;
- Improve the performance of your automated tools.
Training
- Provide annual AML / CTF refresher courses;
- Design and facilitate tailor-made training solutions;
- Conduct specific training workshops for Board of Directors or Compliance staff;
- Provide e-learning programs;
- Ongoing compliance coaching.
Audit / due diligence management support
Provide centralised AML reports that can be shared with all the AML / CTF auditors you have to deal with. These reports provide you with:
- factual comparison of your AML / CTF policies and procedures to key Luxembourg AML / CTF laws and regulations;
- for an agreed sample of investors, factual comparison of documents on file versus documents required by AML / CTF laws and regulations.
AML Distributor Due Diligence
- At the initial set-up of your company's Distributor Due Diligence procedures:
- We train your Board of Directors, Management and Compliance staff in all AML / CTF matters.
- We evaluate your current distribution oversight model.
- We assess the AML / CTF risk of your distribution network and help you prioritise your Due Diligence exercise.
- We review the AML / CTF clauses of your distribution agreements.
- We advise you on how best to enter new markets, combining our expertise in Luxembourg AML / CTF regulations with specific knowledge of local markets.
- We perform country risk assessments.
- We help you understand local legislation: we compare your target countries' legislation to Luxembourg AML / CTF legislation, determining gaps and similarities.
- When carrying out initial Distributor Due Diligence:
- We train and support your internal audit / compliance teams to carry out initial Distributor Due Diligence.
- We help you understand how to get the right identification documentation for global and foreign distributors (i.e. evidence of existence, reputation checks, company structures).
- We review the Distributor's AML / CTF procedures, carrying out a gap analysis to ensure compliance with Luxembourg and EU regulations.
- We make sure that procedures are implemented correctly.
- We visit your local distributors on site.
- For distributors working with Luxembourg funds, we write ISAE 3000 Due Diligence Reports on AML / CTF procedures.
- Ongoing Distributor Due Diligence:
- We provide ongoing Distributor Due Diligence compliance support.
- We visit your local distributors with the support of the PwC network, locally.
- We update our review of your distributors' AML / CTF procedures.
- We test samples of your investor identification documentation locally at your distributor's.
