AML/CFT supervision in the Collective Investment Sector during the COVID-19 situation

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CSSF published a document which purpose is to be quickly disseminated to the employees of supervised entities involved in the Collective Investment Sector (“CIS”). It is designed to provide sector specific details to the CSSF circular 20/740. The idea to design this document appeared in the Expert Working Group AML OPC composed of representatives of several fund industry associations as well as service providers and the FIU. The members recognized that in those difficult times, a ready-to-use document be used as part of the remote training process implemented by the entities so that all their lines of defense remain abreast of the implications of the Covid-19 situation in the fight against money laundering and terrorism financing. The document demonstrates that there is nothing really “new” created by this Covid-19 outbreak, however, a conjunction of factors increased existing threats and vulnerabilities in the CIS.