AML/CFT: CSSF to further enhance its supervision within the Collective Investment Sector

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AML/CFT: CSSF to further enhance its supervision within the Collective Investment Sector

24 January 2020

Regulatory News Alert

Context and objectives 

On 17 January 2020, the Commission de Surveillance du Secteur Financier (CSSF) published Luxembourg’s first money laundering (ML) / financing of terrorism (FT) risk analysis on the Collective Investment Sector. 

The analysis is intended to link the National Risk Assessment of money laundering and terrorist financing (NRA), published in December 2018 that assesses Investment Fund Managers situated in Luxembourg to the specific assessment of the Collective Investment Sector being a sub-sector of the Luxembourgish financial industry. 

It develops a more granular and systematic perspective on the risks faced by the Collective Investment Sector, providing for a non-exhaustive list of predicate offences perpetrated within collective investment to help the participants of the Collective Investment Sector to better identify the risks and promote a stricter compliance risk culture.

Moreover, this assessment, targeting all Luxembourg regulated undertakings for collective investments with a focus on Investment Fund Managers (IFM) and other market participants such as service providers, significantly examines ML/FT inherent risks. It also considers risk-mitigating factors applied by IFM and competent authorities, in view of their specific AML/CFT roles and responsibilities in the sector including the Financial Intelligence Unit as well as their impact on inherent risk and the resulting residual risk levels.

The CSSF expects supervised entities involved in the Collective Investment Sector to reflect the findings and conclusions from this sub-sector risk assessment into their own risk assessment to ensure their framework remains appropriate to effectively mitigate ML/FT risks. 
 

How can Deloitte help?

Deloitte’s advisory specialists and dedicated services can help you design and implement your business strategy in light of the evolution of regulatory frameworks and market trends.

Deloitte’s AML/CTF advisory specialists and dedicated services will also help you design and implement your renewed business strategy in light of the future evolution of the AML/CFT framework.

Key Deloitte AML services are:

  • AML/KYC remediation plan
  • AML/CTF training
  • AML/CTF policy, procedure, and process design or review
  • Assistance in the Money Laundering/Terrorist Financing risk assessment drafting
  • DKYC: externalizing KYC processes

With our Regulatory Watch Kaleidoscope service, Deloitte also helps you stay ahead of the regulatory curve to better manage and plan upcoming regulations.

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Contacts

Subject matter specialists

Pascal Eber
Partner – Operations Excellence & Human Capital 
Tel : +352 45145 2649
peber@deloitte.lu

Eric Collard
Partner – Forensic & AML, Restructuring
Tel : +352 45145 4985
ecollard@deloitte.lu

Bastien Collette
Director – Advisory & Consulting (AML/CTF)
Tel : +352 45145 3372
bacollette@deloitte.lu

Maxime Heckel
Director – Advisory & Consulting (AML/CTF)
Tel : +352 45145 2837
mheckel@deloitte.lu

Alice Lehnert
Director – Advisory & Consulting 
Tel : +352 45145 2605
alehnert@deloitte.lu


Regulatory Watch Kaleidoscope service

Simon Ramos
Partner – IM Advisory & Consulting Leader
Tel : +352 45145 2702
siramos@deloitte.lu

Jean-Philippe Peters
Partner – Risk Advisory
Tel : +352 45145 2276
jppeters@deloitte.lu

Benoit Sauvage
Director – Regulatory Watch services coordinator
Tel : +352 45145 4220
bsauvage@deloitte.lu

Marijana Vuksic
Manager – Strategy, Regulatory & Corporate Finance
Tel : +352 45145 2311
mvuksic@deloitte.lu

 

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