Practices and Recommendations aimed at reducing the risk of ... - Alfi

guidelines
Practices and Recommendations
aimed at reducing the risk of
money laundering and terrorist
financing in the Luxembourg
Fund Industry
in association with 1

www.cssf.lu
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Intermediary
Investor
Screening against sanction and PEP lists
Drives level of
KYC and sets
level for
transaction
monitoring
Risk Assessment:
Composite of:
• Type of person/entity
• Type and nature of
business
• Jurisdiction/supervision
• Ownership and
management structure
• Customer base
• Reputation
• AML and CTF
policies/procedures
• AML
investigations/sanctions
• Type, purpose, and
anticipated activity
• Distribution channel
• Transactions
Risk Assessment:
Composite of:
• Type of
person/entity
• Jurisdiction
• Type of business
• Ownership &
management
structure
• Type, purpose, and
anticipated activity
• PEP
• Source of
funds/wealth
• Distribution channel
• Transactions
Low Risk Medium High
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Minimum Due Diligence Obligations
EEA/EU/Equivalent
Intermediary
Adaptation of the extent of normal due diligence measures on a risksensitive
basis on the Intermediary.
AND
Enhanced due diligence measures on the Correspondent Relationship.
RIN Intermediary
Normal due diligence on the Intermediary.
AND
Enhanced due diligence measures on the Correspondent Relationship with
written documentation of the AML/CTF responsibilities of the
Intermediary.
Intermediary in
jurisdiction with strategic
AML/CTF deficiencies
(Categories 3 and 4 in
section V.E.)
nhanced due diligence on the Intermediary (including certification of
relevant identification documents of the Intermediary).
AND
Enhanced due diligence measures on the Correspondent Relationship with
detailed written documentation of the AML/CTF responsibilities of the
Intermediary.
AND
Intermediary’s written commitment to provide relevant Customer due
diligence data to the UCI/Professional upon request.
Intermediary in
jurisdiction subject to a
FATF call on its members
and other jurisdictions to
apply counter-measures
to protect the
international financial
system from the on-going
and substantial money
laundering and terrorist
financing risks emanating
from the jurisdictions
(Category 5 in section
V.E.)
As part of the counter-measures to protect the financial system from the
on-going and substantial money laundering and terrorist financing risks,
no Correspondent Account will be opened. The UCI/Professional is
responsible for the due diligence on the underlying Investor of the
Intermediary, as defined in the Regulation.
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© ALFI July 2013. All rights reserved.
The practices and recommendations outlined in this document are adopted by the
Association of the Luxembourg Fund Industry (ALFI), the Luxembourg Bankers’
Association (ABBL), the Association of Luxembourg Compliance Officers (ALCO) and the
Association of Professionals in Risk Management, Luxembourg (ALRiM).
Practices and Recommendations
aimed at reducing the risk of money laundering and
terrorist financing in the Luxembourg Fund Industry
guidelines
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