AML/CFT/CPF for Investment Funds, ManCos and AIFMs Luxembourg
The following information is provided for general informational purposes and does not form part of our editorial content. It relates to our professional services in Financial Crime.
The services described are provided by
concilio et labore GmbH,
which was founded by Bastian Schwind-Wagner. Bastian is a Certified Anti-Financial Crime Professional (CAFCP), a qualification validated by TU Dublin.
Overview
Investment funds in Luxembourg operate within a regulatory environment that places strong emphasis on effective AML/CFT/CPF governance, risk-based controls, and demonstrable oversight by management companies and alternative investment fund managers (AIFMs). The AML/CFT/CPF obligations of funds go beyond mere formal compliance. They require the active involvement of management bodies in overseeing, for example, investor due diligence, delegation arrangements and the effectiveness of controls. Supervisory expectations focus on whether AML/CFT/CPF frameworks are tailored to fund structures, investor profiles, and distribution models, and whether responsibilities are clearly allocated and exercised in practice.
The Luxembourg fund AML/CFT/CPF environment
Luxembourg regulated investment funds are subject to EU AML/CFT/CPF requirements and local supervisory expectations that emphasise substance and accountability.
Management companies and AIFMs are expected to:
- maintain a documented, fund-specific AML/CFT/CPF risk assessment
- ensure robust investor KYC and ongoing due diligence
- exercise effective oversight over delegated AML/CFT/CPF activities
- maintain clear governance and reporting arrangements
- evidence ongoing monitoring and remediation
AML/CFT/CPF frameworks must be capable of withstanding supervisory review and inspection.
Common AML/CFT/CPF challenges for investment funds
Investment funds often face AML/CFT/CPF challenges arising from delegation models, cross-border distribution, and diverse investor bases.
Typical supervisory focus areas include:
- adequacy of investor due diligence and risk classification
- oversight of transfer agents and other service providers
- clarity of roles between the fund, the ManCo or AIFM, and delegates
- documentation of governance, oversight, and challenge
- inspection readiness and remediation capability
Addressing these challenges requires a fund specific and proportionate approach.
Our AML/CFT/CPF services for investment funds in Luxembourg
We support investment funds, management companies, and AIFMs in establishing, reviewing, and strengthening AML/CFT/CPF frameworks tailored to the Luxembourg fund environment.
Our services include:
- design and enhancement of fund-specific AML/CFT/CPF frameworks
- AML/CFT/CPF risk assessments for funds, ManCos and AIFMs
- investor KYC and due diligence support
- oversight frameworks for delegated AML/CFT/CPF activities
- review of AML/CFT/CPF policies, procedures, and governance
- support with remediation and CSSF/AED inspections
Our approach focuses on practical implementation and supervisory defensibility.
Governance, delegation, and oversight
Delegation is a defining feature of the Luxembourg fund model. While operational AML/CFT/CPF tasks may be delegated, regulatory responsibility remains with the management company or AIFM. Supervisory expectations focus on how oversight is exercised, documented, and reviewed. We support funds in establishing proportionate oversight arrangements that are clearly evidenced and sustainable.
Inspection readiness and ongoing compliance
Supervisory inspections and thematic reviews increasingly assess AML/CFT/CPF frameworks within fund structures. Funds, management companies, and alternative investment fund managers (AIFMs) must be able to demonstrate effective governance and oversight, as well as the ability to implement timely remediation. We support these entities in preparing for inspections, addressing findings and maintaining ongoing compliance.
How this service fits within our broader Anti Financial Crime offering
AML/CFT/CPF for investment funds is closely linked to investor due diligence, AML/CFT/CPF risk assessment, oversight of delegated functions, AML/CFT/CPF governance, and inspection preparation. These areas are addressed on dedicated service pages within our Anti-Financial Crime offering.
Contact and next steps
If you are reviewing your fund AML/CFT/CPF framework, responding to supervisory feedback, or preparing for inspection, a structured and proportionate approach is essential.