The posting
We are looking for a Senior AML/KYC Officer to join a Luxembourg-based specialised PFS operating within the Private Capital fund administration space, covering Private Equity, Real Estate, Infrastructure and Private Debt.The role combines hands-on AML/KYC expertise, investor due diligence and senior-level oversight, with exposure to sophisticated investors and complex, multi-jurisdictional structures. You will work closely with the RR/RC and senior management, acting as a key escalation point on complex and high-risk matters.Key Responsibilities• Own the investor onboarding and KYC process, from documentation and risk classification through to approval and set-up.• Perform and review CDD/EDD on complex and high-risk investors, including UBO identification across multi-layered structures.• Conduct PEP, sanctions and adverse media screening, investigate alerts and document decisions.• Assess Source of Wealth / Source of Funds, investor eligibility and reliance on third-party or delegated CDD.• Monitor AML risks throughout the investor lifecycle, including capital calls, distributions, transfers, novations and bank account changes.• Review AML considerations across Private Equity, Real Estate, Infrastructure and Private Debt structures, including SPVs, feeders, co-investments and other holding structures.• Contribute to the ML/TF risk assessment, investor risk methodology and periodic/eventdriven KYC reviews.• Investigate unusual activity and support the RR/RC with suspicious activity reporting and regulatory requests.• Maintain and enhance AML/CFT policies, procedures and controls in line with the Luxembourg regulatory framework and CSSF requirements.• Ensure the effective application of the four-eyes principle, conduct quality reviews and follow up on remediation.• Prepare AML/CFT reporting, KPIs and KRIs for senior management and the Board.• Support CSSF inspections, audits and AML incident management.• Deliver AML/CFT training and act as a technical escalation point for the wider administration team.• Act as a key KYC contact for investors, GPs, AIFMs, depositaries and legal advisers.Profile• 7+ years of experience in AML/KYC, including at least 4 years in Luxembourg.• Background in fund administration, transfer agency, AIFM/ManCo or a regulated PFS.• Strong exposure to Private Capital investors, ideally across Private Equity, Real Estate, Infrastructure and/or Private Debt.• Proven experience with complex multi-jurisdictional structures and UBO analysis.• Strong technical knowledge of Luxembourg AML/CFT requirements applicable to fund administration and investor services.• Hands-on expertise in EDD, PEP and sanctions screening, Source of Wealth / Source of Funds and ongoing KYC monitoring.• Good understanding of closed-ended fund mechanics, including commitments, capital calls, distributions, transfers and subscription lines.• Experience interacting with CSSF, CRF, auditors and/or depositaries.• Ability to review fund documentation such as LPAs and subscription agreements from an AML perspective.• Fluent English, with strong analytical skills, rigour and independence.• A confident and challenging approach, with the ability to escalate issues and decline relationships where regulatory requirements are not met.As a Bonus• CAMS, ICA or LSFI/ABBL AML certification.• Experience with KYC/screening and transfer agency platforms such as eFront Invest, Investran, Allvue or equivalent.• Exposure to Private Debt, Real Estate or Infrastructure counterparty due diligence.• Experience in building, enhancing or migrating an AML framework.• French and/or German.



