AMLRO (RC) Service – HACA Partners Luxembourg

AMLRO (RC) Services

Independent AML Oversight. Structured Reporting. Embedded Expertise.

Strategy RC Mandate, RC Support, AML Screening Services

The Luxembourg regulatory framework such as the Article 4 (1) of the AML/CFT Law dated 2004 as amended imposes a clear obligation on investment funds, management companies, and regulated entities to appoint a dedicated AML/CFT Compliance Officer (Responsable du Contrôle, RC). Fulfilling this role effectively requires not only technical expertise but also genuine independence, structured oversight, and the capacity to engage meaningfully with boards, senior management, and supervisory authorities.

HACA Partners has developed a comprehensive AMLRO service offering that addresses this obligation across its full spectrum — from taking on the RC mandate directly, to providing targeted operational support to existing compliance officers, and deploying our proprietary screening technology for investor and asset due diligence. Our model is built around independence, expertise, and pragmatic delivery — giving boards and management the confidence that their AML/CFT obligations are being handled at the highest level of professionalism.

1. RC Mandate — Outsourced AML Compliance Officer

For investment funds, AIFMs, and other regulated entities that wish to delegate the RC function to an independent and experienced external provider, HACA Partners can assume the full RC mandate in compliance with CSSF Regulation 12-02. This service is designed for entities that require a robust, credible, and fully accountable AML oversight function without building the capacity in-house.

As your outsourced RC, we assume full responsibility for the AML/CFT oversight function, including:

• Acting as the designated Responsable du Contrôle (RC) vis-à-vis the CSSF, the AIFMD supervisory chain, and the board of directors, with full accountability for the AML/CFT compliance framework.

• Providing genuine independence in our controls and assessments — as an external party, we bring an additional layer of scrutiny that is structurally free from internal conflicts of interest or operational pressures.

• Delivering quarterly board reporting through a structured, purpose-built AML dashboard covering key risk indicators, investor due diligence metrics, screening outcomes, suspicious transaction activity, and overall AML/CFT risk exposure — enabling the board to maintain real-time visibility of AML risks at all times.

• Conducting the annual AML/CFT risk assessment and updating the risk appetite statement in line with evolving regulatory expectations and the entity’s risk profile.

• Supervising and monitoring delegates and sub-delegates to whom AML functions have been assigned, ensuring that the oversight chain remains robust and documented.

• Preparing and submitting the annual AML/CFT report to the relevant supervisory authorities (CSSF or AED), ensuring full compliance with reporting deadlines and content requirements.

• Leading the investigation and enhanced due diligence process for high-risk investors, including the escalation of red flags and the documentation of risk-based decisions.

• Reviewing and updating AML/CFT policies, procedures, and internal controls on a periodic basis to reflect regulatory developments and changes in the entity’s risk environment.

This fully outsourced model allows boards and senior management to delegate with confidence, knowing that the RC function is held by professionals with deep Luxembourg AML/CFT expertise and a proven track record of regulatory engagement.

2. RC Support — Operational Assistance to Existing Compliance Officers

For entities that have appointed an internal RC but require additional capacity, specialist expertise, or structured support to fulfil their obligations, HACA Partners provides a tailored RC support service. This model positions our team as a technical partner to the RC — taking on the preparation of key deliverables and ensuring that the compliance function operates to the highest standard.

Our RC support services include:

• Preparation of quarterly board reports, including the drafting and structuring of the AML dashboard and supporting commentary, ready for review and sign-off by the RC.

• Drafting and filing of the annual AML/CFT report to the CSSF or AED, including the narrative sections, statistical data, and regulatory disclosures required by the applicable reporting framework.

• Conducting enhanced due diligence investigations on high-risk investors, documenting findings, and formulating risk-based recommendations for the RC’s decision.

• Preparing and updating AML/CFT policies and procedures, including the risk appetite statement, in line with the latest regulatory requirements and supervisory expectations.

• Conducting the annual AML/CFT risk assessment for the entity, covering inherent risk factors, control effectiveness, and residual risk conclusions.

• Supervising and reviewing the AML activities performed by delegates and sub-delegates on behalf of the RC, ensuring that the oversight and documentation trail is complete and audit-ready.

This model is particularly well-suited to management companies or investment firms where the RC holds the function alongside other responsibilities, or where temporary capacity gaps arise due to staff turnover or increased regulatory workload.

3. AML Screening Services

Effective AML compliance relies on the quality and timeliness of screening — both at onboarding and on an ongoing basis. HACA Partners provides dedicated AML screening services powered by our proprietary screening technology, enabling regulated entities to meet their due diligence obligations with precision, efficiency, and full documentation.

Our screening services cover:

• Investor screening: systematic screening of investors — individuals, legal entities, and beneficial owners — against global sanctions lists, PEP databases, adverse media sources, and other relevant watchlists, both at onboarding and on a periodic basis.

• Asset screening: screening of underlying assets, counterparties, and related parties for funds and investment vehicles to identify exposure to sanctioned entities, high-risk jurisdictions, or reputational risk factors.

• Ongoing monitoring and alert management: continuous screening of the investor and counterparty base with structured alert review, escalation workflows, and documented resolution of screening hits.

• Screening framework design: for entities wishing to build or strengthen their in-house screening capability, we provide advice on tool selection, process design, workflow integration, and calibration of screening parameters.

• Screening-related regulatory reporting: support in documenting screening outcomes for inclusion in board reports, annual AML reports, and regulatory submissions.

Our screening service is designed to integrate seamlessly with the RC mandate and RC support offerings described above — creating a fully joined-up AML/CFT service that covers oversight, reporting, and operational due diligence within a single, coherent framework.

The Edge We Bring

Independence

As an external provider, we bring a structurally independent perspective to the RC function. Our assessments, controls, and reporting are free from the internal pressures and conflicts of interest that can affect in-house compliance functions — providing boards and management with an additional, credible layer of AML/CFT oversight that strengthens the overall governance framework.
Expertise

Our team combines deep technical knowledge of Luxembourg’s AML/CFT regulatory framework — including CSSF Regulation 12-02, FATF standards, and the 2025 Luxembourg NRA — with hands-on experience in delivering the RC function across investment funds, AIFMs, and other regulated entities. We translate regulatory complexity into structured, actionable compliance.
Pragmatic Solutions

We focus on what works operationally. Our dashboards, reports, and procedures are designed to be immediately usable by boards and compliance teams — clear, structured, and proportionate to the entity’s risk profile. We ensure that AML compliance is embedded into day-to-day operations rather than managed as a separate administrative burden.
Tailored Approach

Every AMLRO mandate is scoped and delivered around the specific risk profile, regulatory perimeter, and operational reality of the client. Whether acting as RC, supporting an existing compliance officer, or providing screening services, our model adapts to your needs — ensuring the right level of support at every stage.
Quality & Continuity

We commit to consistent, high-quality delivery across all AMLRO engagements. Our clients benefit from stable, experienced teams who maintain continuity of knowledge and relationship over time — building institutional understanding of the entity’s risk environment and ensuring that AML/CFT oversight improves year on year.