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Anti-Money Laundering and Counter Terrorist Financing (AML/CFT) Audit for IFM…are you ready for it?

In brief

As most of you have probably heard by now, a fundamental, regulatory change concerning the Long-Form Audit for Luxembourg IFMs and investment funds is planned. Specific CSSF Circulars defining the requirements in detail are expected to be issued. An AML/CTF audit for supervised, authorised and registered IFMs will become mandatory. The expected application currently, as at date of this mail, is for IFMs with a financial year end December 2021.

In detail

Knowing that this change will mean increased scrutiny of your AML regulatory framework through an annual external AML audit of the IFM – it may be wise to anticipate this change and get ready for it

The CSSF announced that a new circular will be issued in 2021, which requires registered ManCos to appoint an independent audit firm to conduct an AML audit of their entity within a short timeframe. While the new work programme has not yet been released to the public, we would like to share with you what we know as of today: 

  • Who is concerned? Management companies subject to Chapter 15 of the 2010 Law,

AIFMs subject to the 2013 Law, self-managed SICAVs and AIFs, Potentially, IFMs originating from outside of Luxembourg and providing management services via a branch in Luxembourg

Attention: Registered IFMs will need to appoint an external Auditor for this new AML audit.

  • When is the first audit? Expected timeline FYE the 31st December 2021 (subject to confirmation by CSSF Circular expected to be issued)

  • And what do I do now? Get ready!

While the exact details of the AML/CTF IFM audit are to be confirmed in the expected CSSF Circular, the AML/CTF legal and regulatory requirements are clear. The question is,  do you feel well-prepared for the scrutiny of an external AML audit? 

If any of the above questions make you nervous, we would be more than happy to help you prepare.  I am happy to connect you to our AML/CTF Partner who is focussed on the IFM Compliance to discuss the requirements. Just reach out to Birgit Goldak, AML Services Partner for AWM and ALTs or her team. Contact details are included below.

1. PwC Luxembourg ( is the largest professional services firm in Luxembourg with 2,800 people employed from 77 different countries. PwC Luxembourg provides audit, tax and advisory services including management consulting, transaction, financing and regulatory advice. The firm provides advice to a wide variety of clients from local and middle market entrepreneurs to large multinational companies operating from Luxembourg and the Greater Region. The firm helps its clients create the value they are looking for by contributing to the smooth operation of the capital markets and providing advice through an industry-focused approach.

2. The PwC global network is the largest provider of professional services in the audit, tax and management consultancy sectors. We are a network of independent firms based in 155 countries and employing over 284,000 people. Talk to us about your concerns and find out more by visiting us at and

Contact us

Birgit Goldak

Partner, Risk Assurance, specialised in AML for the Asset Wealth Management industry, PwC Luxembourg

Tel: +352 49 48 48 5687

Sandrine Lilliu

Director, PwC Luxembourg

Tel: +3524948483187

Jonathan Walter

Senior Manager, PwC Luxembourg

Tel: +352 49 48 48 2786

Mykyta Bieliakov

Manager, PwC Luxembourg

Tel: +352 49 48 48 2983

Dorit Hornung

Manager, PwC Luxembourg

Tel: +352 49 48 48 4055

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