About this role
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.