Senior AML/KYC Officer (m/f)

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.