Anti Money Laundering (AML) for Funds - Implementation

After completing this course, participants will be able to understand:

• The regulatory framework AML and CFT responsibilities
• The risk-based approach
• The due diligence process on direct investors, correspondents, third party introducers, etc.

• Regulatory Framework
  • General overview of the AML/CTF legislation in place, i.e laws versus grand ducal regulation versus CSSF circulars and regulations
  • Other standards to take into consideration: FATF, Wolfsberg
  • The upcoming 4th AML directive in a nutshell
  • The 2006 ALFI guidelines versus the 2013 ones
• Anti Money Laundering and Combating Terrorist Financing Responsibilities
  • Role, responsibilities and obligations of each actor, (i.e. the management company, the transfer agent, the global distributor and the distributors, the custodian bank)
  • What are the links and interactions between the different actors, who relies upon whom, key questions to ask?
  • Practical examples
• The Risk Based Approach (RBA)
  • Definition of the RBA principles, reference to FATF and Wolfsberg guidance
  • Key criteria for an efficient RBA
  • What are the benefits?
• The Due Diligence Process
  • Definition and application
  • A process applicable to the different actors
  • Different types of due diligence linked to different type of risks
  • Risk assessment and ongoing monitoring
• Direct Investor Due diligence
  • Definition and application
  • Practical examples
• Correspondent Relationship Due Diligence
  • Definition and application
  • Practical examples
• Third Party Introducers and Outsourcing
• Questions and answers