Allianz Global Investors GmbH ”Luxembourg Branch fined EUR 283,000
18/04/2025
A fine imposed by Luxembourg's financial services regulator, CSSF, on the Luxembourg subsidiary of the Allianz Group has become public after a court dismissed an appeal.
On 25 March 2022, the CSSF imposed an administrative fine of EUR 283,000 (two hundred eighty-three thousand euros) on Allianz Global Investors GmbH, Zweigniederlassung Luxembourg ( the ”Luxembourg Branch”) for non-compliance with several professional obligations regarding the prevention of money laundering and terrorist financing, as identified by the CSSF during its on-site inspection.
The inspection revealed several compliance breaches with anti-money laundering and terrorist financing regulations. Notably, the firm's risk analysis did not adequately account for over 1,000 individuals who invested directly in the funds managed by the branch.
Additionally, deficiencies were identified in the company's due diligence procedures for direct and intermediary investors. Also, Allianz failed to conduct name screenings against PEP and financial sanctions lists for five investor accounts (including the absence of senior management approval and poor documentation). At the time of the inspection, the firm did not have an internal AML audit review cycle and did not conduct such audits in 2019 or 2020, despite CSSF requirements.
No matter what jurisdiction you operate in, this is another reminder of the fundamental compliance requirements covering due diligence, ongoing monitoring, senior management's approval for high-risk customers (e.g., PEP), record retention, and audits.
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.