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Ch. 15ADVANCED ~25 mins

AML / KYC / Sanctions

Investor onboarding, beneficial ownership, PEPs & escalation

CDD
Customer Due Diligence. The baseline identification, verification, purpose, and control-chain work required before accepting the investor relationship.
EDD
Enhanced Due Diligence. Deeper review and stronger evidence where risk is elevated, for example due to PEP links, complex structures, or higher-risk geographies.
UBO
Ultimate Beneficial Owner. The natural person who ultimately owns or controls the investor, whether through equity, voting, contractual rights, or another control route.
PEP
Politically Exposed Person. Someone entrusted with a prominent public function, plus relevant family members and close associates under the applicable rules.
Source of funds
Where the subscription money for this transaction comes from.
Source of wealth
How the investor accumulated the broader wealth that makes the investment plausible.
Reliance
Using a third party such as a distributor or intermediary for parts of the AML/KYC process while retaining responsibility for the outcome.
Ongoing monitoring
Reviewing the relationship after onboarding through periodic refresh and event-driven triggers such as ownership changes, sanctions hits, or unusual activity.
Sanctions screening
Checking the investor and relevant connected persons against restrictive-measures lists and resolving matches before and after onboarding.
FIU / STR
Financial Intelligence Unit / Suspicious Transaction or Activity Report. The escalation route when suspicion crosses the reporting threshold.
Ready to practice?
You are: AML/CFT Officer
A layered investor file lands with nominee chains, higher-risk geography, and possible sanctions or PEP exposure · 10+ decision points

Interactive · ~25 minutes · CSSF / EU / FATF AML source pack

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Related Chapters
Key Legislation
§Law of 12 November 2004 on the fight against money laundering and terrorist financing
§CSSF Regulation No 12-02
§Grand-ducal Regulation of 1 February 2010
§Directive (EU) 2015/849
§Regulation (EU) 2024/1624 and Directive (EU) 2024/1640
§CSSF FAQ on AML/CFT Market Entry Form and persons involved in AML/CFT for funds / IFMs