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On 15 December 2017, the CSSF has imposed a fine to Victory Asset Management S.A., an investment fund manager subject to Chapter 15 of the Law, within the context of the management of portfolios of investments, in accordance with mandates given by investors on a discretionary, client-by-client basis (article 101 (3) (a) of the Law). The fine has been imposed on the basis of Articles 148(1)(f), 148(2)(k) and 148(4)(e) of the Law for non-compliance with several professional obligations with regard to AML/CFT requirements as set forth in the Law of 12 November 2004 on the fight against money laundering and financing of terrorism, the Grand-ducal regulation of 1 February 2010 providing details on certain provisions of the Law of 12 November 2004 and the CSSF Regulation 12-02 of 14 December 2012 on the fight against money laundering and terrorist financing. For further details, please refer to http://www.cssf.lu/fileadmin/files/Publications/Communiques/Communiques_2017/CP1744_panama_papers_201217.pdf.