Compliance

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Our compliance process

1. Diagnosis

We take in charge the case and analyse the structure according to our process:

  1. Implementation of a decision matrix between the different bodies of the structure - this will be the basis for future monitoring;
  2. Establishment of a functions’ matrix: Who does what and are there any functions that can’t be held by a single person;
  3. Establishment of an identification file of parties to ensure that all contracts are in place (use of a customer identification form which is tailored to each customer, especially if there are distributors);

2. On-going process

  1. Compliance Dashboard recapitulating the 3 main controls’ types:
    • Legal: Set-up and existence of contracts, compliance with laws and circulars;
    • Operational: Compliance with existing procedures;
    • Organisational: Set-up of a decision and control structure in line with CSSF Circular 12/546.
  2. Monitoring of all legal reporting
  3. Regular reporting to Conducting Persons (monthly) and BoD in a pre-agreed format.

3. Regulators

  • Annual compliance reporting to the Regulator.