At a conference organized by Creobis on the 9th of March, experts and regulators reviewed the implementation of the Luxembourg AML/CFT regulation in the investment funds industry.
The panel was composed of Bastien Collette (Partner at Palana) as moderator, Stéphanie Castryck (Director at HACA Partners and Co-Chair of the AML Technical Committee of LPEA), Anouk Dumont (Deputy Director at FIU), Christian Schaack (Head of AML/CFT division at CSSF), Steven Curfs (Conducting Officer & RC at Engelwood Asset Management) and Sylvain Aubry (Chief Compliance Officer MIBL). The panel discussed, among others, the following topics:
– The coexistence of the Circular CSSF 18/698 and the Regulation CSSF 12/02;
– The practical approaches to perform AML due diligence on assets;
– The feedback on the declarations made to the FIU;
– The integration of the evolution of the roles, tasks and responsibilities of RRs and CRs; and
– The allocation of responsibilities between the AIFM, the depositary, the central administration, the transfer agent, etc.
Stéphanie Castryck concluded the conference by a presentation of the AML/CFT key focal points and the key reporting dates not to be missed this year 2023.