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By Christophe Wintgens, Partner, Wealth and Asset Management Leader and Christine Frentz, Associate Partner, Audit, EY Luxembourg
Since the dawn of the COVID-19 pandemic, perpetrators of financial crime have taken advantage of the resulting economic instability and uncertainty. An increase in the use of digital payments, the rising popularity of virtual currencies, and the accelerated rate of technological advancement have all aided criminals in finding new opportunities to launder money at greater speeds and larger volumes.
To counter this risk, the Luxembourg regulator CSSF, issued Circular 21/788 in December 2021 which, alongside Circulars 21/789 and 21/790, reinforces the regulatory requirements for investment fund managers (IFMs), as...
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