Back to Chapter
The Layered Investor FileYou are: AML/CFT Officer
0:00
0/8
THE SITUATION

A private-bank distributor sends a subscription file for a new investor into your Luxembourg fund. The proposed investor is a corporate vehicle with nominee layers, a higher-risk jurisdiction link, and an individual behind the structure who may have a public-office connection. Sales wants the file accepted before quarter-end close. You need to decide whether the fund can onboard, what is missing, and where to escalate.

YOU ARE:AML/CFT Officer