Description
Job Overview
We are seeking a Fund Compliance Officer & Responsable du Contrôle to join our team in Luxembourg. This is a newly created role within Carta Lux S.à r.l., a CSSF-licensed Specialised PFS providing fund administration, transfer agency, domiciliation, and related services to alternative investment funds.
Responsibilities
As our Fund RC, you will:
- Accept formal appointment as Responsable du Contrôle for a portfolio of Luxembourg-domiciled investment funds administered by Carta Lux
- Maintain and annually update each fund's AML/CTF policies and procedures, risk appetite statement, and business-wide risk assessment (BWRA)
- Develop, update, and execute the AML/CTF compliance monitoring plan for each fund mandate; propose and track remediation plans where gaps are identified
- Maintain and update investor due diligence questionnaires; ensure all investor files are current and appropriately risk-scored
- Perform AML delegation oversight of transfer agents and other key stakeholders, including periodic due diligence and review of AML/CTF SLAs
- Oversee investor and asset due diligence across the fund's operating model; ensure KYC files are kept up to date in line with the fund's risk-based approach
- Report to fund boards on a quarterly and annual basis; prepare and present RC reports and attend board meetings in your capacity as appointed RC
- Oversee the AML external audit of each fund in accordance with CSSF Circular 21/790 and applicable CSSF/AED regulatory requirements
- Act as the primary regulatory liaison for each fund mandate: handle CSSF and AED surveys, data calls, and ad hoc regulator requests; ensure timely FIU reporting in respect of suspicious transactions
- Assess regulatory developments affecting fund AML/CTF frameworks and translate them into policy and process updates
- Deliver AML/CTF training to fund boards, Carta Lux colleagues, and other relevant stakeholders
- Support the onboarding of new RC mandates, including the buildout of fund-level AML documentation and policies
Requirements
- Must hold the right to work in Luxembourg
- At least 7 years of professional experience in AML/CFT, with demonstrable exposure to the Luxembourg alternative fund industry
- Prior authorisation or eligibility for approval by the CSSF and AED to act as Responsable du Contrôle for funds; previous RC appointment experience is strongly preferred
- Solid knowledge of Luxembourg AML/CFT legislation and regulatory requirements applicable to fund structures (RAIFs, SCSps, SICARs, SIFs, and equivalent vehicles)
- Comfortable operating at board level: clear communicator, capable of presenting RC reports and managing senior stakeholder relationships
- Organised and detail-oriented, with the ability to manage multiple mandates simultaneously and meet regulatory deadlines
- Excellent command of English required; French is an advantage