KYC Analyst / AML-CTF Compliance Officer

Herbert Smith Freehills Kramer is a world-leading global law firm, where our ambition is to help you achieve your goals.

Exceptional client service and the pursuit of excellence are at our core. We invest in and care about our client relationships, which is why so many are longstanding. We enjoy breaking new ground, as we have for over 170 years.

As a fully integrated transatlantic and transpacific firm, we are where you need us to be. Our footprint is extensive and committed across the world’s largest markets, key financial centres and major growth hubs.

At our best tackling complexity and navigating change, we work alongside you on demanding litigation, exacting regulatory work and complex public and private market transactions. We are recognised as leading in these areas.

We are immersed in the sectors and challenges that impact you. We are recognised as standing apart in energy, infrastructure and resources. And we’re focused on areas of growth that affect every business across the world.

All of this is achieved by supporting the growth of our people, who help us deliver on our ambition – which is to help you achieve yours.

Herbert Smith Freehills Kramer: Your goals. Our ambition

The Opportunity

Primary Objectives

Supporting the Luxembourg office of the Firm in meeting its professional obligations under Luxembourg anti-money laundering and counter-terrorist financing legislation, in particular the amended law of 12 November 2004, related Grand-Ducal regulations, applicable EU AML measures and the AML/CTF obligations applicable to lawyers under the supervision and guidance of the Luxembourg Bar Association.

The role will focus on exercising the KYC process for the firm, including client due diligence processes, client and beneficial owner identification and verification, risk assessment, sanctions and PEP screening, ongoing monitoring and record keeping alongside advising the MLRO and other Partners on the applicable AML/CTF obligations and requirements of the firm.  This will include escalating to internal stakeholders any risks identified as part of KYC for review and approval and will support the designated MLRO in drafting and submitting, where appropriate, suspicious activity reports to the Luxembourg Financial Intelligence Unit (CRF).  

Key Responsibilities:

• Assist the Firm in complying with Luxembourg AML/CTF and KYC obligations applicable to legal professionals, using a risk-based approach tailored to the client, matter type, jurisdiction, ownership structure and source of funds/source of wealth indicators.

• Perform client due diligence (CDD) and, where required, enhanced due diligence (EDD) on new and existing clients, including identification and verification of clients, beneficial owners, controlling persons and authorised signatories.

• Screen clients, counterparties and connected parties against sanctions lists, PEP databases and adverse media sources, including EU, UN and other relevant international sanctions regimes, and escalate potential matches in accordance with internal procedures.

• Analyse Luxembourg and foreign corporate documentation, structure charts, RCS/LBR extracts, RBE information and other reliable, independent sources to establish ownership and control, including complex structures involving funds, holding companies, SPVs, trusts, foundations or regulated entities.

• Advise lawyers and business services colleagues on KYC, AML/CTF and onboarding requirements applicable to Luxembourg legal services, including when additional documentation, explanations or approvals are required before opening or continuing a matter.

• Ensure KYC files are complete, accurate, audit-ready and maintained in accordance with the Firm’s internal procedures and Luxembourg record-keeping expectations.

• Support ongoing monitoring and periodic reviews of client relationships, including trigger-event reviews linked to changes in ownership, control, activity, risk profile, sanctions status or the nature of the matter.

• Assist with the identification, internal escalation and documentation of unusual or suspicious activity and contribute, where applicable, to suspicious transaction/activity reporting processes involving the Luxembourg Financial Intelligence Unit (CRF).

• Maintain awareness of Luxembourg and EU AML/CTF developments, including updates to the law of 12 November 2004, EU AML regulations/directives, sanctions measures, guidance from the Luxembourg Bar Association and relevant expectations from Luxembourg supervisory authorities and where necessary, provide analysis of potential impacts to the KYC process so that any remediation or changes can be made in a timely manner

• Contribute to continuous improvement of Luxembourg onboarding workflows, templates, checklists, internal guidance and management information for local and global risk stakeholders.

Qualifications/ Skills / Experience

• University degree in law, finance, risk management, compliance or a related field; a professional AML/KYC certification such as ICA or ACAMS would be an advantage.

• Previous experience (3+ years) in KYC, AML/CTF, compliance, client onboarding or risk within a Luxembourg law firm, professional services firm, financial institution, fund service provider or regulated environment.

• Good knowledge of Luxembourg AML/CTF requirements, including the amended law of 12 November 2004, client due diligence, beneficial ownership identification, PEP and sanctions screening, enhanced due diligence and ongoing monitoring.

• Understanding of Luxembourg corporate and funds structures, including holding companies, investment funds, SPVs and cross-border ownership chains, with the ability to identify practical KYC risks and documentation gaps as part of KYC client due diligence process.

• Excellent research, analytical and judgement skills, with strong attention to detail and the ability to document conclusions clearly.

• Ability to work autonomously, prioritise competing requests and manage deadlines in a fast-paced legal services environment.

• Strong communication skills and confidence liaising with partners, lawyers and business services teams on sensitive regulatory matters.

• Excellent written and spoken English and French; Luxembourgish and/or German would be an advantage.

• High level of discretion, integrity and professional judgement when handling confidential client and matter information.

Team

Location

Contract type

Diversity & Inclusion

We are committed to attracting people from all backgrounds and creating a respectful and inclusive culture where everyone thrives. We see this as essential to our success, including our ability to innovate and achieve sustained high performance. This is a key part of our Values—Human, Bold, and Outstanding.