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ALFI : new blunder about Madoff (update)

The ALFI’s task force issued a report on Madoff that was presented last Friday. The report states two key initiatives: publication of a code of conduct stamped Alfi, having to list the best practices and recommendations for a better governance as regards investment fund; and the making of a guide of good practices as regards the depositary (see Paperjam and LFF)


Publication of a code of conduct stamped ALFI?


But they used to have one…  that was unfortunately withdrawn.


Let’s have a look at their publications.


July 2001

While ALFI's board of directors and president have changed, the Association's ambitions remain unchanged. We want to anticipate and prepare the future by putting in place training programs for the young professionals of our industry, by educating the investors, by implementing the code of ethics and guidelines for auto-regulation, by working out meaningful statistical data and feasibility studies



November 2001

A Code of Ethics for the Luxembourg Investment Fund Industry

Not a new idea, but a new emphasis. The will to implement the highest standards for the whole financial sector is of primary importance to the Luxembourg fund industry. In 1998, ALFI issued a code of ethics which set up rules for the various actors in the investment fund industry, whether located in the Grand Duchy or active in Luxembourg from abroad. The main goal of this code of ethics is explicitly to provide additional protection to investors


Annual report 2001

Revision of ALFI's Ethical Code

The "ethical code" sub-committee of the Legal Committee has initiated a revision of ALFI's ethical code. In fact the Association's current ethical code dates from 1998 and concentrates mainly on questions related to the prevention of money laundering, insider trading offences and investor information. Although no disciplinary proceedings are planned and CSSF has not wished to make this code compulsory for the whole investment fund sector, all institutions or investment funds which have joined ALFI should, in principle, comply with this ethical code. Since the adoption of this regulatory corpus, several circulars relating to deontology have been published by the supervisory authority, in particular circular 2000/15 based on the law transposing the Directive on Investment Services and concerning the rules of conduct applicable to professionals in the financial sector.

Of course this circular is only addressed to financial sector professionals (FSPs), but as ALFI's ethical code covers all those involved in the investment fund industry, the working group has considered it useful to adapt it in accordance with the rules of

conduct issued by CSSF.

The members of the working group have decided to continue to set out in detail the obligations of each category of investment fund professionals and not to adopt the process set out in circular 2000/15, which describes these obligations on an issue by issue basis.




The problem is that I had noticed in 2006, that their code was no longer online.


It was replaced by external codes that were never ever appropriated.



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