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This document was prepared by ALFI’s Anti-money Laundering Working Group jointly with ABBL, ALCO, LPEA and LuxReal. The working group comprises of representatives of asset managers, management companies, securities service firms, audit firms and law firms.
The Reviewed Practices and Recommendations aimed at reducing the risk of money laundering and terrorist financing in the Luxembourg Fund Industry present the working group’s interpretation and understanding of the anti-money laundering and counter terrorist financing framework for the securities sector in Luxembourg. These guidelines have not been validated by any regulator. It is the responsibility of each stakeholder to comply with applicable rules on the fight against moneylaundering and terrorist financing. This document must not be relied upon as advice and is provided without any warranty of any kind and neither the participating associations nor their members who contributed to this document accept any liability whatsoever for any action taken in reliance upon it. UCIs and Professionals should refer to their legal advisor for all general advice on AML and CTF matters.This document is drafted on the basis of rules in force at the time of publication. It is worth noting that during the drafting process ALFI submitted a number of questions for discussion and common understanding to the CSSF AML Experts Working Group.