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By Maxime HECKEL, Julia BESSMERTNYKH, Etoile ROSE, Gabriela de LEÃO GALÁN, Deloitte Luxembourg*
In the ever-evolving landscape of the investment fund industry, regulatory compliance remains a critical but sometimes not fully comprehended topic. In Luxembourg the CSSF Circular 18/698 and the CSSF Regulation 12-02, as amended, are setting the regulator’s requirements and expectations on market players, including investment fund managers (IFMs) and IFM delegates. Aiming to serve as a beacon, the Association of the Luxembourg Fund Industry (ALFI) released a guideline in May 2021, outlining practices and recommendations based on AML/CTF requirements and practical applications for the fund industry. However, market actors still face challenges in implementing these...
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