Regulatory & Compliance

We steer you towards Regulation in Motion

Outsourcing of the RC function with AML/CFT experts

Our team of experienced experts is setting-up the AML/CFT RC Function for 60+ AIFM and/or funds by:

- Drafting / reviewing the AML/CFT Policy

- Drafting / reviewing the Risk Appetite Statement

- Drafting / updating the ML/TF Risk Assessment

- Drafting the Annual AML/CFT Report

- Registering as RC on GoAML

- Submitting the CSSF or AED annual survey

- Performing AML/CFT controls 

- Escalation point for high-risk accounts

- Facilitating the AML/CFT training

- Performing oversight on the transfer agent and any other AML delegate of the investment funds

- Performing due diligence reports on high risk assets and investors

- Providing the Board and/or the RR with appropriate reporting

AML/CFT RC Services

R&C Consulting Services

Bridging the gap between regulatory challenges and their implementation

Our team of 15+ staff with more than 8 years of averaged experience delivers high quality gap analysis and provides you tailored made and practical solutions for more than 60 clients. Amongst the projects we are working on, we can list: 

- Impact assessment of regulatory challenges on business model

- In-depth analysis of existing processes and operating models

- AML/CFT assistance (AML/CFT policies, procedures, Risk Appetite, Risk Assessment, AML/CFT Tax gap analysis,...)

- Drafting manual of procedures and policies 

- Leading/participating in the implementation of regulatory projects (e.g. AML/CFT, EMIR)

- Leading/participating in due diligence (initial or periodic) exercises on delegates

- Forensic services

- Training facilitation


Integrating approach to solve your requirements with regulator

We have developed a pragmatic approach of responsiveness to Luxembourg regulators for our clients’ needs by a large range of services:

- Licensing assistance

- Market Entry Forms completion

- AML/CFT external audit

- Self-Assessment questionnaire

- Governance, AML/CFT or thematic mock inspections

- Assistance in the answer to the Regulator's requests 

- Annual AML/CTF Report and/or Compliance drafting


Regulator interfacing

Wishing to reinforce your workforce with experts

We reinforce your team by bringing expertise, trust and experience with flexible profiles (including conducting officers or board members) on various subjects such as:

- AML/CFT

- GDPR

- Transaction monitoring

- Compliance monitoring

- Regulatory requirements


Outsourcing

Our team

Saïd Hadji

Managing Partner

Member of the IIA and ALCO, Saïd has 15 years of professional experience serving financial services firms in Luxembourg, mainly banks, management companies and PSF.

Saïd built a robust experience in auditing and advising clients for a “Big Four” firm in Luxembourg. He also had the opportunity to practice the Internal Audit function in major banks active in wealth management in Luxembourg.

Saïd is the Managing Partner at HACA Partners and is mainly involved in Regulatory & Compliance, Risk Management and Internal Audit engagements.

Cédric Leroy

Partner

Cédric is a Réviseur d’Entreprises Agréé in Luxembourg since 2012 and gained international experience in Luxembourg and in London in audit and tax matters within a “Big 4” serving important Swiss, US and UK origin Asset Managers mainly in mainstream fund and in the alternative world.

Cédric completed his experience with 4 years at the Commission de Surveillance du Secteur Financier (CSSF) by carrying out more than 20 on-site inspections on the governance of investment fund managers and covering legal and regulatory subjects including AML/CFT.

Cédric was also part of the Circulars CSSF 20/744, 21/789 and 21/790 writing and implementation process.

Stéphanie Castryck

Director

Stephanie is a Certified Anti Money Laundering Specialist (CAMS), Co-Chair of the AML group of the LPEA, member of the Association Luxembourgeoise des Compliance Officers (ALCO) and the Expert AML-OPC working with the CSSF.

Stephanie has launched the RC services (Responsable du Contrôle des obligations AML for investment funds) within an important AIFM and service provider in Luxembourg in 2020 and has 20 years of expertise in alternative investments funds (mainly PE/RE) and AML – KYC matters.

Stephanie is approved and registered as RC by the CSSF and the AED.

Kirtana Bhoojedhur

Senior Manager

Kirtana is an ACCA member since 2020 and has an accumulated experience of 8 years, and these include extensive experience in financial due diligence, AML/KYC, Compliance reviews, internal and external audits, implementation of procedures and forensic engagements and extensive reviews of business models. She has also gained international experience in Malaysia, Mauritius, Union of Comoros and Madagascar.

Kirtana also acquired banking experience, by joining the Strategy team of Banque Internationale à Luxembourg as Project manager.

Kirtana is now part of the Regulatory & Compliance team at HACA Partners, being also involved in Consulting and Risk management projects.

Hélène Fischer

Senior Manager

Hélène started her professional experience as a consultant within a Big Four located in Luxembourg, working in Regulatory Consulting for Investments Funds sector and serving important European, Swiss and US origin Asset Managers dealing mainly in UCITS funds and in the alternative world for various type of missions (fund structuring, regulatory gap analysis, regulatory watch, licensing / agreement obtention).

Hélène completed her professional path with 7 years as compliance officer within a Luxembourg management company belonging to a Swiss private banking group; carrying out the implementation of the compliance monitoring plan, and then AML/CTF monitoring controls. Her functions also covered risk assessments, procedures updates, regulatory reporting, regulatory watch.

Lazzat Nurmagambetova

Senior Manager

Lazzat has an accumulated experience of 14 years with a record of success ensuring organization adhere to external regulatory requirements and internal policies, including providing compliance support for asset management companies in Luxembourg, establishing frameworks to ensure compliance with the listing requirements and other regulations post-IPO for companies within energy sector in Kazakhstan. Lazzat has gained expertise in banking as the Head of Legal at Kazakhstan Development Bank.

She is well-versed in analysing risk tolerance and exposure, establishing risk mitigation infrastructures, and deploying controls, processes, and action plans that strengthen corporate compliance.

Lazzat is an active member of the Association Luxembourgeoise des Compliance Officers (ALCO).

Laurence Ponchaut

Senior Manager

With an MBA from INSEAD and a degree from Solvay Business School, Laurence has built her career in consulting by serving European clients from Luxembourg.

She started her career with Deloitte and then PWC, mainly in the financial sector, before joining the strategy department of Clearstream. Laurence has gained extensive experience in assurance as an auditor for a governmental organisation in Luxembourg for the last 10 years.

She has also developed a strong expertise in GDPR over the last few years by carrying out GDPR assignments in the financial, insurance and personnel management sectors.

Camille Salagnac

Senior Manager

Camille built her professional experience as Chief Compliance Officer for a bank in Luxembourg, after 5 years of financial/regulatory audit and compliance consulting at PwC, serving major Swiss, US, Luxembourg and French banks, Fintechs, PFS and asset management companies.

Thanks to these experiences, Camille has acquired skills, in particular in the areas of anti-money laundering and terrorist financing, MiFID, market abuse, anti-corruption and anti-fraud. She is familiar with the electronic banking and monetary regulatory environments and their recent developments.

Finally, Camille is used to giving training to internal and external stakeholders on various compliance-related topics.

Corinne Sinclair

Senior Manager

Corinne is an experienced professional in Compliance and AML/KYC with over 18 years of expertise in the financial sector.

Currently leading the compliance department and AML obligations, Corinne has a solid record of managing complex regulatory environments. Her skills include drafting AML policies, risk assessments, and forensic AML investigation.

Corinne's leadership has extended to mentoring teams, establishing departments, and ensuring regulatory adherence. She excels in beneficial ownership determination and have a knack for solving intricate financial crime cases.

Overall, Corinne is a compliance leader with a proven ability to navigate diverse challenges.

Raquel Tchaptchet

Senior Manager

Raquel is a Certified Anti-Money Laundering Specialist and a Certified Global Sanctions Specialist. She is also a member of the ALCO.

Raquel holds a Master degree in Insurance and Risk Management from the University Paris Dauphine.

Raquel has an experience of 10 years of which 7 servicing the Luxembourg Financial Services Industry (Banks, PSF, Management Companies, Alternative Investment Fund Manager,…). On top of her background as Regulatory & Compliance Manager, Raquel brings actual experience from Internal Audit.

Emir Hayta

Manager

Emir gained a professional experience of 7.5 years in investment funds industry. She started her professional career as a consultant within a Big Four located in Luxembourg, working in the advisory department in fund distribution and serving European and non-European asset managers dealing with various fund structures. Her functions also covered due diligence on stakeholders and regulatory watch.

She completed her professional path in depositary services for an American depositary bank located in Luxembourg, carrying out mainly the oversight duties for asset managers.

Ishfaaq Hossen

Manager

Ishfaaq was an Audit Manager in Luxembourg and gained extensive knowledge of Accounting Frameworks, including Lux GAAP and IFRS as well as application of the theories in practice. He also has expertise on different components/mechanism and laws applicable in Asset and Wealth Management industry funds.

Through studies and experience, Ishfaaq built a good understanding of portfolio theory, investment analysis and budget planning. He also has an aptitude in Activity Based Management and TQM, and can evaluate various contemporary performance measurement and management frameworks (englobed in alternative management accounting).

Ishfaaq also has an extensive knowledge of Mathematics (calculus, matrices, probability, cryptography and number theory).

Younia Mlanao

Manager

Graduated with a Master’s degree in Management and Finance from Grenoble Ecole de Management, Younia joined a Big Four Luxembourg in external audit missions specialized in Banks and PSFs.

Then, she was part of the finance department of a bank in Luxembourg providing knowledge and expertise for ongoing compliance projects.

Through these experiences, she expanded her knowledge on the financial actors in Luxembourg and the regulations that applied. Finally, Younia is a trained Project Manager from Luxembourg Chambre de Commerce.

Sophie Seck

Manager

Sophie holds a Master in Wealth Management with double majors in Banking and Finance from INSEEC Bordeaux. She also obtained an ACAMS certification in KYC CCD fundamentals in 2020 and the ICA certification in compliance in 2018.

Sophie has an accumulated experience of 10 years, and these include extensive experience in financial due diligence, AML/KYC, Compliance reviews within banks and Fintech, in Europe and Africa.

In her previous experiences, she was in charge of the transactions monitoring, the onboarding and due diligences for several companies and individuals based in America, Europe and Africa, review of SPAs, monthly/annually reports and internal/external trainings . Sophie is now part of the Regulatory & Compliance team at HACA Partners and she is already approved RC for 3 supervised entities.

Sophie is an active member of the Association Luxembourgeoise des Compliance Officers (ALCO).

Dahlia Uwiragiye

Manager

Dahlia has more than 10 years of experience in the financial services industry (external audit, internal audit as well consulting).

She spent several years in a Big 4 audit firm and gained experience on external audits mostly on Investment Funds including CSSF supervised entities and other non -regulated funds (UCITS, FoF, hedge funds...).

Her other areas of expertise include regulatory compliance in a large Luxembourg based management company as well as internal audit working in the education sector.

Olivier Daraize

Senior Consultant

Olivier has more than 6 years of experience in Compliance and AML for PSF and Investment Funds in Luxembourg and more than 10 years in the financial industry.

He has a strong knowledge in AML/KYC, Compliance reviews, Compliance Monitoring Plan .

In his previous experience he was in charge of the transactions monitoring, the onboarding and due diligences for several companies and individuals, monthly/annually reports and internal. He was also in charge of implementing new compliance tools.

Youssef Housni

Senior Consultant

Youssef has more than 7 years of experience with a background in legal studies. With a Master’s degree in criminal sciences from the university Hassan II, Casablanca, Morocco and a Mater’s degree in Litigation law from the University of Toulon, France, He embarked on a career in compliance, specialized in Anti-Money Laundering (AML) and Know Your Customer (KYC) processes.

Foteini Markaki

Senior Consultant

Foteini is an EU qualified lawyer registered with the Athens Bar Association. During the first years of her career, she practiced actively law in Athens, Greece.

In 2015, Foteini landed in Luxembourg and gained practical experience working for international clients in law firms and CSSF supervised entities. Her experience lies in dealing with the company law aspects of entities flowering in the alternative investments' ecosystem and the regulatory aspects of mainstream or semi-regulated funds under the scope of the IFM.

Foteini continues to stay up-breast of the developments at EU and international levels by attending the Executive LLM of LSE covering all the upcoming hot issues in the world of traditional finance combined with the emerging technologies.

Mathilde Nicolas

Senior Consultant

Mathilde holds a Master degree in Negotiation and Wealth Management obtained in a work-study program at Société Générale in France.

Mathilde worked 4 years at Société Générale in France as Wealth Management advisor. She was in charge of a portfolio of around 900 clients. Mathilde’s clients were mainly medium clients (between EUR 50,000 and EUR 200,000 of balance).

Mathilde was responsible of the daily management of those clients (e.g. investment advice, sell of Société Générale products and services,…).

Mathilde is devoting 50% of her time in the day to day Compliance of HACA Partners by reviewing all acceptance of new client with Cyril Cayez and 50% of her time in the regulatory watch or client support in compliance.

Elisabeth Verdoni

Senior Consultant

Elisabeth has more than 4 years of professional experience as Compliance Officer in Luxembourg.

Abdoulaye Barry

Consultant

Abdoulaye has nearly 4 years experience in compliance in the banking & fintech industry. He has held positions in various banks in Senegal, as well as in a fintech specialized in cross-border payments.

Jade Cupilari

Consultant

Jade has worked in a Fiduciary where she had the opportunity to discover several AML and Compliance services before joining HACA Partners in Regulatory & Compliance.

Among these services, Jade has been involved in several assistance projects in Fund Administrative, Transfert Agent, KYC Assistance, Compliance and Regulatory & Compliance.

Amandine Rinaldi

Consultant

Amandine has more than 3 years of experience in Compliance in Banks, Fintech and Manco.

She has a strong knowledge in financial due diligence, AML/KYC, Compliance reviews in banks and Fintech.

In her previous experience she was in charge of the onboarding and the due diligences on investments Fund with high exposure to Private Equity and Venture Capital investment structures, with emphasis to alternative investments funds.

Léa Zanon

Consultant

Léa holds in Master in accounting, control and Audit that she obtained in 2023.

Léa has 2 years of experience as an Accountant in an accounting and audit firm where she had a portfolio of small sized compagnies and high wealth self-employed clients (doctors, solicitors).

For them, she was in charge of the client daily management (accounting entries, communication) and of the annual and periodic reporting (tax and VAT declarations, annual accounts etc…). She was very autonomous in her tasks.

She also is a volunteer firefighter.