Anti-Money Laundering and Counter-Terrorism Financing for UCITS/AIFs

Not a day goes by when financial and non-financial media do not make reference to the intention of politicians, economists and law makers to strengthen the current measures against money laundering (AML) and terrorism financing. More and more sanctions are imposed for the non-respect of AML and terrorism financing duties by financial supervisory authorities and by judges.

An efficient participation in the fight against money laundering and terrorism financing implies a good knowledge of the existing laws and regulations but also of the permanent professional duties. Faced with increasing regulatory duties, the management and the employees are often overwhelmed and cannot meet said duties if they have not been clearly defined.

As part of this course, PwC's Academy offers to highlight your company's requirements regarding this topic and to address in a comprehensive and practical way the questions participants are confronted with in the light of mandatory professional duties and the "progressive" evolution of AML regulations. This particular course specifically addresses to employees working in the funds industry.

Thanks to our strong expertise in the financial sector and our professional experience, we can help participants improve their AML knowledge according to the best practices.

By the end of this training, participants will be able to:

• identify the impacts of the regulatory requirements on their organisation;
• set up and apply a risk based approach;
• extend the procedures applicable to a Luxembourg entity to an international group;
• explain the relevant regulations and the possible consequences of negligence or breach to other employees;
• draw up an internal AML framework in line with the requirements;
• draw up the internal AML assessment.

Our training is focused on:

• answering legal requirements;
• taking into account the latest legal and regulatory international, European and Luxembourgish changes and the latest CSSF and FIU circulars, regulation and annual reports;
• giving concrete examples extracted from the press and from the professional experience of speakers within the funds industry;
• a pragmatic approach to elaborate duties depending on participant activities and organisation's size.

Theoretical part

• Development of essential definitions
• Overview of the recent regulatory environment at Luxembourgish, European and international levels
• Scope of primary offences

Practical part

• Presentation of professional obligations and illustration with practical examples from the funds industry
• Customer due diligence (identification and verification of the identity, name checking, origin of funds,... for individuals and legal persons)
• Criteria related to the “risk-based approach” (nationality, country of residence, professional activity, PEP etc.)
• Transaction monitoring (incoming, outgoing, name and country screening, amount, frequency, IT tools etc.)
• How to cooperate with the FIU (who, when, what, “no tipping off” principle)
• Adequate internal organisation (framework, IT tools, record keeping) and controls (hierarchical, internal audit, compliance function etc.)

Focusing on UCITS and alternative investments funds industry, this training is interactive and full of useful practical points, multiple-choice questionnaires and case studies.

An attendance certificate will be sent to participants.

This training is coordinated by Cécile Moser and Michael Weis, Partners at PwC Luxembourg and will be given by directors and managers who benefit from a strong professional experience in this area.

Cécile, AML Services Partner, is specialised in the financial sector of Luxembourg, with a particular focus on AML and CTF regulations and internal control environments.

She manages and performs regulatory mandated AML and CTF reviews, identifies AML and CTF control issues or deficiencies for private banks, custodians, transfer agents, investment funds and management companies.

Cécile also provides advice on AML and CTF methodology and helps to develop AML/CTF procedures in line with local laws and regulations.

Michael, Financial Crime Leader and Partner in the forensic services, gained extensive knowledge in the investment management and banking industries.

As a key member of the internal controls practice of PwC, Michael specialises in the review of internal controls in the context of SAS 70 reviews and controls reports. He is the manager of various high-profile client assignments on internal controls reports and on Anti-Money-Laundering (AML) in the investment management industry.

Within PwC, Michael takes a key role in the AML taskforce and on internal controls work for the prevention of financial crime. He is coordinating the PwC’s Academy's “Fight against financial crime” leading training programmes that regularly involve international subject matter experts (e.g. transparency international, UN Security Council, FATF, SCPC, FSA, CSSF etc.).

Through his professional qualifications he specialises in compliance related topics such as internal controls frameworks, fraud prevention/investigation and AML.