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AML/CFT Policy template for Luxembourg entities
The framework document the RR signs and the inspector reads first. Structured on CSSF Regulation 12-02 and the Law of 12 November 2004, with the governance, risk-based approach, CDD, sanctions, reporting and record-keeping chapters every Luxembourg professional must have.
- 42 pages
- .docx
- 12 months of updates
What's included
- Word document · 42 pagesEditable .docx, highlighted fields, optional blocks marked.
- 12 months of regulatory updatesNew versions with a change note, in your account and by email.
1. Purpose, scope and legal framework
2004 Law art. 1–2; Reg. 12-02 art. 1–3Covers the entity, its activities, delegated functions and the hierarchy of sources.
2. Governance: board, RR, RC, compliance function
Reg. 12-02 art. 40–42; CSSF FAQ persons involvedRoles, appointment, reporting lines, independence, annual RC report.
3. Risk-based approach and link to the BWRA
2004 Law art. 2-2; Reg. 12-02 art. 4–5How the policy consumes the BWRA outputs and sets risk categories.
4. Customer due diligence: standard, simplified, enhanced
2004 Law art. 3, 3-1, 3-2; Reg. 12-02 art. 6–33Triggers, timing, UBO identification, PEPs, reliance on third parties.
5. Sanctions and asset-freezing measures
Law of 19 Dec 2020; EU regulationsScreening, hits handling, reporting to the Ministry of Finance.
6. Suspicious transaction reporting to the CRF
2004 Law art. 5; goAMLInternal escalation, tipping-off, record of the decision not to report.
7. Record keeping and data protection
2004 Law art. 3(6); GDPRFive-year retention, deletion, register of steps.
8. Training, review cycle and version control
Reg. 12-02 art. 43–44Annual review, change log, board approval block.
Watermarked preview of the first pages. The full document is 42 pages.
| Obligation | Law of 12 Nov 2004 | CSSF Reg. 12-02 | Section |
|---|---|---|---|
| Risk-based approach | 2004 Law art. 2-2 | Reg. 12-02 art. 4–5 | §3 |
| Customer due diligence | 2004 Law art. 3 | Reg. 12-02 art. 6–33 | §4 |
| PEP measures | 2004 Law art. 3-2 | Reg. 12-02 art. 30–31 | §4.5 |
| RR/RC designation | 2004 Law art. 4 | Reg. 12-02 art. 40–42 | §2 |
| Record keeping | 2004 Law art. 3(6) | Reg. 12-02 art. 37 | §7 |
| Training | 2004 Law art. 4(1) | Reg. 12-02 art. 43 | §8 |
- Editable .docx (Word 2016+, Google Docs, LibreOffice). Fields to complete are highlighted in yellow; optional blocks are marked [IF APPLICABLE].
- Instant delivery: download link by email and permanent access in My documents.
- 12 months of regulatory updates included. Each update comes with a change note.
- Invoice with your VAT number issued automatically at checkout (Stripe Tax, reverse charge for EU B2B).
- Single-entity licence. Group licence and ManCo multi-fund licence available on request.
Read the guide: CSSF Regulation 12-02 explained
Frequently asked
Which vehicles does the fund variant cover?
UCITS, Part II, SIF, SICAR (CSSF supervision) and RAIF and unregulated SCSp (AED supervision). The legal framework chapter, supervisor references and reporting section change with your selection.
Does it cover the ManCo/fund split?
Yes. The fund variant includes the delegation clause to an AIFM or ManCo and to a registrar/transfer agent, with the oversight controls the fund keeps.
How long does adaptation take?
Buyers report two to four hours for a standard structure. Fields to complete are highlighted; optional blocks are marked.