practices and recommendations aimed at reducing …...management structure • customer base •...
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Practices and Recommendationsaimed at reducing the risk of money laundering and terrorist financing in the Luxembourg Fund Industry
guidelines
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Intermediary Investor
Risk Assessment: Composite of:
• Type of person/entity • Type and nature of
business • Jurisdiction/supervision • Ownership and
management structure • Customer base • Reputation • AML and CTF
policies/procedures • AML
investigations/sanctions • Type, purpose, and
anticipated activity • Distribution channel • Transactions
Risk Assessment: Composite of:
• Type of person/entity
• Jurisdiction • Type of business • Ownership &
management structure
• Type, purpose, and anticipated activity
• PEP • Source of
funds/wealth • Distribution channel • Transactions
Low Risk Medium High
Drives level of KYC and sets level for transaction monitoring
Screening against sanction and PEP lists
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Minimum Due Diligence Obligations
EEA/EU/Equivalent Intermediary
Adaptation of the extent of normal due diligence measures on a risk-sensitive basis on the Intermediary. AND Enhanced due diligence measures on the Correspondent Relationship.
RIN Intermediary
Normal due diligence on the Intermediary. AND Enhanced due diligence measures on the Correspondent Relationship with written documentation of the AML/CTF responsibilities of the Intermediary.
Intermediary in jurisdiction with strategic AML/CTF deficiencies
(Categories 3 and 4 in section V.E.)
nhanced due diligence on the Intermediary (including certification of relevant identification documents of the Intermediary). AND
Enhanced due diligence measures on the Correspondent Relationship with detailed written documentation of the AML/CTF responsibilities of the Intermediary. AND Intermediary’s written commitment to provide relevant Customer due diligence data to the UCI/Professional upon request.
Intermediary in jurisdiction subject to a FATF call on its members and other jurisdictions to apply counter-measures to protect the international financial system from the on-going and substantial money laundering and terrorist financing risks emanating from the jurisdictions (Category 5 in section V.E.)
As part of the counter-measures to protect the financial system from the on-going and substantial money laundering and terrorist financing risks, no Correspondent Account will be opened. The UCI/Professional is responsible for the due diligence on the underlying Investor of the Intermediary, as defined in the Regulation.
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Practices and Recommendationsaimed at reducing the risk of money laundering and terrorist financing in the Luxembourg Fund Industry
guidelines
© ALFI July 2013. All rights reserved.
The practices and recommendations outlined in this document are adopted by theAssociation of the Luxembourg Fund Industry (ALFI), the Luxembourg Bankers’Association (ABBL), the Association of Luxembourg Compliance Officers (ALCO) and the Association of Professionals in Risk Management, Luxembourg (ALRiM).
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