AML CFT Compliance
ML / TF Advisory Services
Growing pressure to adhere to Money Laundering (ML) and Terrorism Financing (TF) laws and regulations has significantly the pressure on the financial sector in Luxembourg. Non-compliance may lead to substantial fines imposed by the CSSF, coupled as well as potential reputational damage.
To ensure compliance with standards, companies are required to take the following essential steps:
- Establishing a robust compliance framework aligned with regulatory standards.
- Enforcing stringent Know Your Customer (KYC) procedures to verify customer identities and mitigate risks.
- Conducting thorough risk assessments and implementing corresponding mitigation strategies.
- Providing training to employees to enhance and maintain their understanding of compliance and risk management.
- Maintaining accurate and updated records of transactions, customer due diligence, and risk assessment findings.
Origo can support you in the production and completion of any of the above tasks.
RC Services
In adherence to ML/TF laws and regulations in Luxembourg, every investment fund and Management Company is mandated to appoint an RC (responsible de contrôle) tasked with the following specific duties:
- Conducting an annual review of the ML/TF Policy.
- Updating the Risk Appetite and Risk Assessment.
- Actively participating in due diligence processes.
- Overseeing ML delegation concerning Transfer Agents, distributors, or Portfolio managers.
- Establishing and maintaining comprehensive investor and asset due diligence procedures.
- Conducting ML risk scoring for investors, distributors, and assets while maintaining updated KYC and Due Diligence records.
- Suggesting and monitoring the progress of remediation plans and their implementation.
- Reporting quarterly and annually to the Board of Directors.
- Responding to CSSF/AED Surveys and data requests.
- Providing internal ML/TF training according to Luxembourg’s regulatory requirements.
Origo’s consultants are qualified to assume the role of RC. Alternatively, we can provide support to an appointed RC in fulfilling any of the responsibilities mentioned above.
ML / TF Training
ML/TF is majorly important for the financial sector. Understanding compliance measures and effectively combating illicit activities within the financial sector is crucial.
Origo provides specialized ML/TF training sessions aligning with CSSF Regulation N°12-02 from December 14, 2012, on combating money laundering and terrorist financing.
Training sessions will usually take place online. Upon request, we can arrange for on-site training at clients’ locations in Luxembourg.
Participants receive a certificate upon successful completion of the training, acknowledging their participation.
Trained by ACAMS
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