DS Compliance

ADVISORY, our core business

Procedures, internal control & internal governance

“Having proper internal governance is fundamental for the durability and the image of your company”.

Our proposal:

  • Compliant-solutions with best market practices in Luxembourg
  • Solutions tailored-made and adapted to your business and structure

How?

  • Drafting or review of the Compliance Manual, including policies and procedures, required or  “good to have”
  • Advice on adequate internal governance for the structure and business
  • Drafting of the Compliance Plan
  • Proposal of relevant controls and monitoring program (recommendations from Auditors and from your supervisory authority, “Commission de surveillance du secteur financier”, “Commissariat aux Assurances”…)

Compliance risk assessment

“Being aware of Compliance risks is the first step to manage them”.

Your challenges:

  • Identify and assess adequately manner your Compliance risks
  • Preserve good repute and image of your company in the eyes of your clients and investors

Our proposal:

  • A global view and clear understanding of your Compliance risks
  • An objective analysis of your Compliance risks (legal, reputation, sanction and financial risks…)

How?

  • Mapping of your compliance risks
  • Impact analysis of such risks for your company and business
  • Proposal of adapted solutions according to your business and company

Anti-Money Laundering & Counter Terrorist Financing

“Your continuous concern: to ensure that the company does not become victim of money laundering and/or terrorist financing and preserve reputation towards your clients and investors”.

Our proposal:

  • Inform about best market practices of Luxembourg
  • Provide tailored-made solutions according to the typology of your clients, products and risks on anti-money laundering & counter terrorist financing…

How?

  • Drafting of on anti-money laundering & counter terrorist financing procedure (risk-based approach, KYC/ due diligence and suspicious transactions...)
  • Drafting of annual anti-money laundering & counter terrorist financing risk assessment
  • Proposal of transactions’ monitoring program (alerts’ system according to clients, products risks and countries of distribution )
  • Gap analysis of internal controls (critical points, sufficiency; relevancy; adaptation)
     
    More specifically, for fund management companies (UCITS, AIF):
    • Gap analysis and due diligence of your funds’ distribution network (in EU and non-EU countries) and due diligence of your transfer agent...
    • Drafting of anti-money laundering & counter terrorist financing clause (Distribution Agreements)

Regulatory assistance

Your challenges:

  • Maintain good relationships with the supervisory authorities, “Commission de surveillance du secteur financier”, or “Commissariat aux Assurances” and the Financial Intelligence Unit…
  • Be well-informed about international, European and national regulatory obligations

Our proposal:

  • The supply of Compliance expertise in areas such as anti-money laundering & counter terrorist financing; MIFID; market abuse; UCITS; AIFM and rules of business conduct (conflicts of interest, remuneration, Code of conduct…).

How?

  • Assisting with communications with the supervisory authorities, “Commission de surveillance du secteur financier”, or “Commissariat aux Assurances” and the Financial Intelligence Unit…
  • Gap analysis and regulatory impact on your business (critical points, sufficiency and relevancy)
  • Proposal of compliant solutions: adaptation of your procedures and internal controls.

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