Luxembourg • Independent • AML/CFT
Independent RC for Luxembourg fund structures
Independent RC/MLRO oversight for Luxembourg fund structures, combining AML/CFT governance, risk-based control, regulatory coordination and board-ready reporting without adding internal complexity.
AIF • RAIF • SIF • SICAV • AIFM
Core responsibilities within the RC mandate
RC oversight,
 structured and under control
Independent RC mandate support for Luxembourg fund structures, with clear AML/CFT control oversight, risk assessment, escalation handling, regulatory and board reporting, recurring AML/CFT training and authority-facing coordination.
01.
AML/CFT Control Oversight
Clear visibility across your control environment
Independent review of the AML/CFT framework, control environment and governance arrangements across the structure.
02.
Risk Assessment & Risk-Based Approach
Issues addressed early, with structured follow-up
Ongoing attention to risk assessment methodology, risk-based controls and the consistency of AML/CFT monitoring across the structure.
03.
Escalation Handling
Clarity for decision-making at board level
Structured handling of issues requiring visibility, remediation follow-up or escalation within the governance chain.
04.
Regulatory & board reporting
Aligned interactions with regulators and stakeholders
Ongoing coordination with regulatory bodies and stakeholders, ensuring alignment and consistency.
05.
Training & Authority-Facing Coordination
Continuous awareness with structured regulatory coordination
Recurring AML/CFT training and awareness-raising, together with structured CSSF and, where applicable, AED-facing coordination across the mandate perimeter.
Understanding the role
How the RC fits within your AML/CFT governance
A clear overview of the RC and RR roles within your governance structure.
RC and RR, clearly defined
The RC is responsible for the control of compliance with AML/CFT obligations across the structure.
Acting within the governance framework, the RC reports regularly to the RR, supports escalation handling, and contributes to board-ready reporting, recurring AML/CFT training and authority-facing coordination.
RR – Responsable du Respect des obligations
The RR may be either one board member individually or the board acting collegially.
Governance line
Why LuxComply fits the mandate
Ecosystem
At the centre of every Luxembourg fund structure
Acting as an independent RC, LuxComply sits at the intersection of the Board, CSSF/AED, competent authorities and key service providers – ensuring clarity, alignment and continuity across your structure.
Approach
A clear, structured approach to RC oversight
Acting as an independent RC requires more than expertise, it demands structure, consistency and clear execution.
Our approach ensures that every aspect of your governance framework is monitored, aligned and under control.
01.
Assessment & Mapping
Understand your structure, AML/CFT perimeter, governance lines and operational setup before acting.
Clear visibility from day one
02.
Monitoring & Control
Ensure continuous oversight of control frameworks, risk indicators, monitoring arrangements and follow-up actions.
Nothing critical goes unnoticed
03.
Escalation
 & Coordination
Structure remediation, stakeholder communication and escalation handling across the governance chain.
Faster, aligned decision-making
04.
Reporting,
Training & Governance
Deliver board-ready reporting, recurring AML/CFT training, clear escalation points and regulatory alignment.
Board-ready execution, consistently
Who leads the mandate
The RC officer at the centre of your structure
Ibrahim Hourfane
Responsable du Controle (RC) – AML/CFT Governance for Luxembourg funds and AIFMs
Luxembourg-based
French . English . Spanish
AML/CFT and compliance professional with leadership experience across Big Four firms and major banking institutions in Luxembourg.
APPROACH
Independent, structured and governance-focused, with particular attention to escalation handling, stakeholder coordination, recurring AML/CFT training and board-ready reporting.
REGULATORY EXPOSURE
Experience interacting with CSSF/AED-facing AML/CFT matters within Luxembourg fund structures.
Why it matters
Why independent RC support matters
Clarity
Independent oversight across AML/CFT controls, governance lines and reporting obligations.
Continuity
Stable coordination across stakeholders, escalation points and governance bodies.
Execution
Operational availability, structured follow-up, recurring AML/CFT training and board-ready communication without internal build-out.
Start the conversation
Discuss your RC mandate with clarity
Whether you are launching a new fund structure or seeking an independent RC for an existing vehicle, we provide a clear, independent perspective on your governance and AML/CFT requirements.
contact@luxcomply.com
Phone
+352 20 60 58 57