Description

Senior Compliance & AML/CFT Consultant with strong experience advising Luxembourg-regulated entities, including Professionals of the Financial Sector (PSF) and Management Companies subject to Chapter 15 of the CSSF Circular 18/698. I have held senior compliance leadership positions, including Chief Compliance Officer, and supported firms in meeting CSSF, AML Law of 12 November 2004, and EU regulatory requirements.

My expertise includes the design, implementation and review of AML/CFT frameworks, KYC and client due diligence, risk-based approaches, transaction monitoring, sanctions and PEP screening, and regulatory reporting to the CSSF and FIU. I regularly assist PSFs and ManCos with AML risk assessments, policies and procedures, compliance monitoring plans, internal controls, and preparation for CSSF on-site inspections and external audits.

I also support management companies with conducting officer duties, compliance function setup or reinforcement, regulatory gap analyses, and implementation of CSSF circulars (including 12/552, 18/698, 20/758 and related guidance). My approach is pragmatic and business-oriented, ensuring regulatory compliance while supporting operational efficiency.

As a freelance consultant, I deliver hands-on, senior-level support for interim roles, regulatory remediation projects, and mission-critical assignments, with a strong focus on professionalism, confidentiality and regulatory credibility in the Luxembourg market.

Languages

Portuguese
Native or bilingual
English
Native or bilingual
French
Native or bilingual
Spanish
Fluent
Italian
Basic

Workplace preferences

Remote only

Primarily works remotely

Moventum Asset Management S.A.
Chief Compliance Officer
PRIVATE EQUITY
July 2023 - November 2025 (2 years and 4 months)
Luxembourg, Luxembourg
- Implementing a Compliance Monitoring Plan;
- Ensuring compliance with regulatory requirements;
- Performing onsite due diligence on service providers;
- Liaising with the regulator in order to ensure a positive onsite visit:
- Managing the application for a financial advisory license;
- Drafting Risk assessments, policies and procedures;
- Preparing presentations on behalf of the company to auditors and to the Luxembourg Financial Markets Authority (CSSF);
- Implementing a regulatory watch;
- Performing investigations on Sanctions and submitting reports to the Luxembourg Financial Intelligence Unit;
- Monitoring transactions and Outsourced Service Providers;
- Drafting and submitting reports to the financial markets regulator;
- Attending Boards of Directors and drafting management minutes;
- Reviewing agreements and Key Performance Indicators;
- Replying to extraordinary audits in the context of an acquisition;
- Reporting Key Risk Indicators;
- Acting as RC of MOVEtogether SICAV and Moventum Plus Aktiv SICAV
Due Diligence Regulatory Compliance AML KYC Screening Governance, Risk & Compliance (GRC)
Amicorp Luxembourg S.A.
Head of Compliance
June 2022 - June 2023 (1 year)
Luxembourg, Luxembourg
• Preparing and submitting the Annual AML-CFT survey;
• Drafting the annual Compliance Function Report to the CSSF;
• Drafting the annual AML-CFT report to the Board of Directors;
• Organising Client Acceptance Committees;
• Issuing recommendations to the board related with regulatory compliance, sanctions and embargoes;
• Completing Due Diligence Questionnaires and organising clients / AIFMs / Depositary banks on-site visits;
• Updating and drafting new KYC Policies and Procedures (Client Onboarding; Telework; Complaints Handling; Corporate Governance; Outsourcing; PEP approval; Client Exit)
• Updating a Compliance Risk Assessment;
• Drafting a new AML Risk Assessment based on CSSF circulars 11/529; 21/782; PFS sub Sector Risk Assessment as well as in the guidelines issued by the Ministry of justice; Ministry of Finance and FATF.
• Drafting and implementing an Assessment tool for Outsourcing Service Providers;
• Providing presentations to the CSSF on behalf of the company;
• Drafting an implementing all sorts of registers (PEPs / Sanctions' lists Audit; Record Destruction; Gifts and Hospitality);
• Drafting and Implementing a new Compliance Monitoring Plan;
• Performing On-site visits on behalf of the Company;
• Performing a Regulatory watch;
• Liaising and ensuring the follow up of internal audit and external audit recommendations;
• Submitting STRs/ SARs to the FIU and transaction reports to the Ministry of Finance;
• Performing spot-checks on transactions as well as on clients' and investors' files
Ocorian (Luxembourg) Services S.A.
RC and Compliance Manager
May 2019 - June 2022 (3 years and 1 month)
Luxembourg, Luxembourg
• Act on behalf of the Head of Compliance for Europe whenever necessary (e.g. in certain group level projects or in Pre-acceptance committees);
• Validating the acceptance of new clients prior to the final acceptance by the members of the Authorised Management Committee;
• Creating a new Onboarding tool integrating both ML and Tax risk assessments based on the requirements of the CSSF Circular 20/744, complementing the circular 17/650;
• Providing support to the IT manager drafting the regulatory and risk assessment framework for cloud outsourcing service providers based on the Circular 17/654 as amended as well as relevant guidelines and FAQs issued by the CSSF.
• Creating and updating new policies and procedures (e.g. Telework policy);
• Updating the company risk assessment tool in accordance with the guidelines of the Specialised PFS risk Assessment;
• Giving presentations on behalf of the company to auditors and to the CSSF;
• Creating and maintaining a Sanctions tracker;
• Ensuring that regulatory watch is done and that key regulatory updates are shared across the company;
• Ensuring that domiciled entities perform due diligence of the investments done by their funds;
• Creating an a Outsourced Service Providers Assessment tool based on a risk scoring model;
• Creating and updating Internal and External Audit Dashboards in order to track and promote the follow-up and closure of audit recommendations.