For twenty years, Luxembourg’s fund industry has built a fortress at the front door: investor KYC, subscription checks and name screening of every LP. Yet dirty money also comes in, and goes out, through the deals themselves: the seller the fund pays, the co-investor at the table, the borrower who repays early, the buyer at exit. The CSSF has named this “other door” in its sub-sector risk assessments and set out what it expects in its FAQ on asset due diligence of 13 December 2024. This three-hour session gives compliance officers, conducting officers, deal teams and boards one question to ask of every asset: who is on the other side of this deal, and where does the money come from and go? It then gives them a seven-step Know Your Asset method to answer it. The session draws on public enforcement cases (1MDB, Och-Ziff, Greensill) and on fictional Luxembourg deal files. It runs in six acts, from the legal framework to the boardroom, with case exercises along the way.
I. The Other Door: why dirty money also comes in through the assets a fund buys, finances and sells.
II. The Rulebook: what Luxembourg and EU law actually require on the asset side, from CSSF Regulation 12-02 to the 2027 AMLR.
III. The Method: Know Your Asset in seven steps (Scope, Map, Screen, Score, Diligence, Decide, Monitor & exit), from the first teaser to the last payment on exit.
IV. The Terrain: where the money hides in private equity, real estate, infrastructure, private debt and natural resources.
V. The Defence File: defence and dual-use investments: legitimate, strategic, and the highest-maintenance assets you will own.
VI. The Boardroom: governance, oversight of delegates, and a capstone investment committee.
