Why Choose AMFIE?

AMFIE’s rates are applied to all savings accounts- regardless of the size of the deposit- and returns are credited each quarter pro rata temporis, i.e. from day one of the deposit to the date of withdrawal. In addition, a bonus is accorded at the end of the year, depending on AMFIE’s results.

At AMFIE transparency is essential. That's why you will not find:

- Fees charged on your interests.
- Limits in the amount of the deposit that can benefit from the remuneration;
- Eye-catching ephemeral rates reserved for new members.
- Hidden fees- all our rates are available on request.
- Minimum investment time- your money is available at any time.

In addition to a savings account, AMFIE also offers you the opportunity to open a 0-18 savings account for your children.

This savings account will be blocked until your child turns 18 and will benefit from a favorable rate reviewed every 6 months, without any management fees.

The opening of a savings account is accompanied by the creation of a multi-currency current account with minimal cost, giving you great flexibility.

All of your accounts can be managed from your mobile phone with the AMFIE application available on Android and IOS. You also benefit from telephone support available during opening hours.

AMFIE is a PSF (Financial Sector Professional) with wealth management firm status. Members’ funds are deposited with Luxembourgish partner banks, which are affiliated with the FGDL (Deposit Guarantee Fund Luxembourg).

The safety and quality of AMFIE’s deposits are also obtained through diversification and the selection of investments from only the best "investment grade" issuers. In addition, members’ deposits are held in the currency(ies) chosen by the member. In other words, when a member makes a deposit in an AMFIE currency, it stays in that currency unless we are instructed otherwise.

The following is a list of our custodian banks as at 8 November 2018

- Banque de Luxembourg
- Banque Internationale à Luxembourg (BIL)
- ING Luxembourg
- Keytrade, Luxembourg
- Natixis, Luxembourg
- Société Générale Bank and Trust, Luxembourg

AMFIE does not use any derivative instruments, such as forward contracts, which carry different risks. Investment criteria are decided by the Board of Directors, elected by the General Assembly, in line with the investment policy as described in the discretionary management mandate signed by all members.

Deposit & Withdrawals

Your money is always available. You may withdraw as much money as you need, when you need it. If your current account does not have enough funds, the money will be debited from your savings account.

Deposits may be made by cheque or bank transfer to one of AMFIE’s accounts. Subject to the rules and regulations related to money laundering, there is no limit to the amount you may deposit in an account.

All deposits are automatically and immediately credited to the member’s current account in that currency unless we are instructed otherwise. You may ask us to transfer these funds to your savings account (on a specific date or on a regular basis).

Withdrawals may be made by standing order instructions, “one-off” transfers or payments to third parties.

If there is not enough money in your current account to cover a transfer, AMFIE can draw the money from your savings account. No fees will be charged.

Most transfers to and from member accounts through our network of correspondent banks are without charge.

Please pay attention to the currency of the AMFIE bank account to which you are sending money. For instance, if you send USD to an account in EUR, the amount will be credited but the bank will charge fees for the foreign exchange.

You can simply ask the Office in Luxembourg and will be charged a 2€ fee for each request.

You can simply ask the Office in Luxembourg and will be charged a 2€ fee for each request.

With a Mastercard or VISA credit card from AMFIE, you can withdraw up to € 1,500 per day. MasterCard/VISA charges for cash withdrawals are € 4 plus 2.5% of the amount withdrawn.

You can also arrange to have up to 10,000 euros (or the equivalent in another currency) in cash available at some of our partner banks. Please notify the Secretariat four business days in advance.

You can ask for a free credit card.

Unfortunately, for security reasons, it is not possible to withdraw cash directly from the Secretariat.

 

AMFIE will send a transfer within two working days of receipt of your instruction. If a simultaneous currency exchange is being requested, this delay is extended to four working days.

You can also arrange to have up to 10,000 euros (or the equivalent in another currency) in cash ready at some of our partner banks. Please notify the Secretariat four business days in advance.

 If you intend to withdraw over € 50,000 or the equivalent in other currencies, the delay is increased by a minimum of five working days.

Transfer: An amount deposited on an AMFIE bank account is credited with a +1 day as value date on the member’s account.

Cheque: AMFIE will wait for the bank’s confirmation that the cheque has been cleared before crediting the amount to the member’s account. This means that members will see cheques credited to their accounts only once payment of the funds has been confirmed (payment will remain subject to the possibility of the issuing bank demanding repayment).

The process can take from three to four weeks.

Cash: An amount deposited on an AMFIE bank account is credited with a +1 day as value date on the member’s account. AMFIE should be informed at least 1 day prior, by completing an origin of funds form.

In the interest of better security, members who wish to make deposits or withdrawals in cash will need to do so directly at the counter of one of our banking partners (the full list is available in the private area of our website).
The AMFIE secretariat is not authorised to handle cash on your behalf.

Just complete and sign a withdrawal form and indicate the name and the account number of the beneficiary.
Via your on line private access: Pre-register the non-AMFIE account number in advance. Then, send your withdrawal request in a few clicks.

In the interest of our members’ security, the secretariat has received clear instructions never to give financial information pertaining to members accounts over the phone.

AMFIE’s online banking service is available without charge and provides full information on members’ accounts, which is updated every day at 8pm.

If a member mentions a figure or information relating to his/her account, then the secretariat may only confirm or deny the information provided without correcting it if incorrect.

You can also ask to receive information by FAX or email (scanned request with handwritten signature).

Savings

The multi-currency savings account is a remunerated account and money is available at any time.

The rate is set on the first day of the quarter for each currency and interest is paid at the end of the quarter.

There is no minimum or maximum amount required for deposits into a savings account.

The AMFIE Flexible Term Deposit offers a higher rate than the savings account.

The investment period is one year and the interest rate is fixed at the beginning of the period; the interest is credited at maturity. In case of early departure, penalties apply.

Like the savings account, there is no minimum amount and no maximum to open a flexible AMFIE.

AMFIE, the savings and investment solutions

Members maintain total control over their own accounts; they make investment decisions and choose which currencies to buy.

AMFIE draws on its collective members’ financial strength to invest with care, thereby earning the best possible inter-bank returns offered by only the highest rated institutions. All other types of investments are made only upon receipt of a member’s specific instruction and under their own responsibility.

Members' savings are directly managed by AMFIE. AMFIE is not authorized by the discretionary management mandate to delegate this task to third-party management companies. The staff dedicated to this task manages the assets in coordination with the treasurer of AMFIE, member of the Board of Directors.

Investment criteria and decisions are continuously reviewed by our Board of Directors, elected by the General Assembly.

Credit Card

AMFIE offers 3 types of credit cards, whose features are explained in the section on Mastercard/Visa.

It will take between 3 to 6 weeks provided that the guaranty is sufficient.

You just need to send AMFIE a signed request asking for the increase of credit limit. The increase will be available within 48 hours (if applicable, the amount of the guaranteed amount will also increase).

Please contact SIX PAYMENT +352 49 10 10

Please send us a signed instruction for a new PIN. You will receive a new PIN code within 10 days.

Please contact SIX PAYMENT +352 49 10 10

AMFIE.NET Access

AMFIE.NET is your online account system. It allows you to add beneficiaries, to transfer funds or to make other operations safely.

This section is only accessible to our members. Please connect to the Member area.​

Why do I have to submit certain documents to AMFIE?

AMFIE is a financial institution bound by Luxemburg law, and as such, it is legally obliged to determine the identity of its business clients and to use suitable means to verify its clients’ identity.

The authority in charge of overseeing Luxemburg financial institutions, the CSSF (la Commission de Surveillance du Secteur Financier [Commission for the Surveillance of the Financial Sector]) has specifically stipulated that AMFIE obtain a certified copy of either the passport or the national ID card of each of its members.

AMFIE is also legally required to submit regular reports on the business relations it has with its members and to submit certain legally required data, which must be regularly updated. This is the reason why AMFIE requires its members to submit a new officially certified copy of their identity document whenever the previous one has expired.

These measures have been put in place by the European regulatory authorities as part of their campaign against money laundering and against financing of terrorist activities.

Legal reference: The Regulatory Act of Luxemburg dated 12/11/2004 in its most recent version.

In order to satisfy anti-money laundering regulations and other requirements set by the Luxembourg regulatory authorities, AMFIE is obliged to obtain a certified copy of your valid passport or national identity card.

This copy must include the document’s number, the bearer’s photo, signature and birth date as well as the validity date.

The certification of the identity document should also include the surname, first name and position of the person who certified the document and the official stamp.

 The certification of your identity document can be done by either:

  1. The Human Resources Director of your organisation,
  1. An authorised official:
  • notary public,
  • police officer,
  • city-hall official,
  • consular official,
  • lawyer.
  1. A person accredited by AMFIE:
  • AMFIE directors,
  • AMFIE coordinators,
  • AMFIE Staff.

 If you  have multiple citizenships, please provide AMFIE with a certified copy of the corresponding passports or national identity cards.

The legislative institutions regulating financial services sector in Luxemburg require financial service institutions to obtain relevant information about their clients before beginning business relations. This is referred to as the “Know Your Customers due diligences”. Proof of a client’s country of residence forms part of the required information.

The residence status information can also be used as an important document for electronic information exchange with different European institutions in financial matters (this is comparable to the use of residence documents for FATCA in the U.S.).

 

The financial information form contains two questions on the use of your account with AMFIE and on the origin of the funds that you plan to deposit into your AMFIE account.

The Luxemburg CSSF has identified this information as relevant for its campaign against money laundering.

 

In this declaration, you state whether or not you are a US citizen within the meaning of the American tax regulation FATCA (Foreign Account Tax Compliance Act).

This tax regulation has been put in place by the Federal Government of the United States of America with the intention of reducing opportunities for tax evasion by American tax payers through the creation of a global information exchange between US financial authorities and financial institutions across the globe, including the Grand Duchy of Luxembourg.

The FATCA agreement requires AMFIE to provide a certain amount of financial data about its account holders who are US citizens. The Luxembourg financial authorities will then transfer this information to the American financial authorities.

The FATCA agreement signed on March 28, 2014 treats any person as a US citizen, if that person has not declared whether or not he or she is a US citizen.

Legal reference: The FATCA (Foreign Account Tax Compliance Act) agreement signed and dated March 28, 2014 by the United States of America and the Grand Duchy of Luxemburg.

This form protects all AMFIE members, whether they are actual investors or only potential investors.

AMFIE is legally required to take note of your knowledge and experience in investment matters as well as your financial situation when creating an investment profile for you.

Once your profile is complete, AMFIE will only offer you products and services that are appropriate for your profile.

Legal reference: Luxembourg Law on Market for Financial Investment, dated July 13, 2007.

This form protects all AMFIE members, whether they are actual investors or only potential investors.

AMFIE is legally required to take note of your knowledge and experience in investment matters as well as your financial situation when creating an investment profile for you.

Once your profile is complete, AMFIE will only offer you products and services that are appropriate for your profile.

Legal reference: Article 54 of the Commission Delegated (EU) of 25 April 2016 supplementing Directive 2014/65/EU of the European Parliament and of Council as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive.

The Capital Adequacy Directive (CAD II) has adopted the Common Reporting Standard (hereinafter CRS), a financial regulation mechanism adopted by the OECD, which requires all countries who have adopted the CRS (hereinafter CRS jurisdiction), such as Luxembourg, to exchange financial information.

Relations between countries outside the EU that have also adopted the CRS are regulated by multilateral agreements.

The CAD II requires AMFIE to document and communicate information on its members, whether they are legal corporations or individuals residing outside its borders and to pass this information on to the Luxembourg financial authorities, who will then communicate it to other countries under CRS jurisdiction.

The data exchanged includes personal details (last name, first name, address, tax reference number, place and date of birth) and details on the accounts you hold with AMFIE (account number, account balance, gross interest paid within a calendar year).

The first data transmission based on CAD II will take place in 2017 and cover the whole of 2016.

This is why AMFIE asks you to fill in the self-declaration of tax residence, including your current tax residence address or addresses and your tax reference number.

If you do not submit this self-declaration, AMFIE may be required to treat you as a tax resident of several countries (in accordance with CAD II) and would then be required to exchange the above-mentioned data with several countries (countries which might not be your actual tax residence).

Legal reference: Luxembourg Law on Automatic Information Exchange on Accounts and Financial Matters dated 18 December 2015.

Some of the European & Luxemburgish rules applicable to AMFIE

If you have questions regarding controls on movements of cash within the European Union, please read the file on this subject as well as Regulation (EC) No 1889/2005 of the European Parliament and of the Council of 26 October 2005 on controls of cash entering or leaving the Community.

The cash withdrawal limit authorised by AMFIE is EUR 10,000 per day and per member, but may be increased / decreased by AMFIE at the discretion of an Authorised Director.

Moreover, the CSSF Regulation 12-02 obliges AMFIE to request, in certain cases, and at its sole discretion, information on the reasons for the transactions planned or carried out.

AMFIE provides information concerning the complicated business of succession when you are an international official.

 ‘Planning cross-border EU inheritance’

Since 2016, Luxembourg has applied a 10% withholding tax on income from indigenous capital assets such as:

  • dividends and other income from shares or units of public limited companies, limited partnerships, limited liability companies and cooperative companies,
  • the profit from shares in a commercial, industrial, mining or artisanal enterprise, remunerated in proportion to the profit,
  • arrears and interest on bonds where, for these securities, there is a right to the allocation, apart from the fixed interest, of an additional interest varying according to the profit distributed.

The rate of withholding tax on movable capital income listed  is set at 15% from 1 January 2007 (20% until 31 December 2006). It is to apply to gross income without any deduction. Some international conventions provide for lower rates of withholding tax and Article 147 of the amended Law of 4 December 1967 concerning income tax (LIR) specifies under which conditions the withholding tax is not applicable.

The income listed is considered to be indigenous when the debtor is the Grand-Ducal State, a municipality, a Luxembourg public institution, a private-law entity with its registered office or headquarter in the Grand Duchy of Luxembourg or a natural person who has in the Grand Duchy of Luxembourg his fiscal residence.

 

Data protection notice

The protection of your personal data is important to AMFIE.

This Data Protection Notice is directed to the members of AMFIE, direct relationships and services providers/vendors of the Association, as well as the persons set out in section 2 (“you”).

This Data Protection Notice provides you with detailed information relating to the protection of your personal data by AMFIE, Financial Cooperative Association of International Civil Servants “AMFIE” or “Association”), 25A, Boulevard Royal L- 2449 Luxembourg (« we »).

We are responsible, as a controller, for collecting and processing your personal data in relation to our activities. The purpose of this Data Protection Notice is to let you know which personal data we collect about you, the reasons why we use and share such data, how long we keep it, what your rights are and how you can exercise them.

Further information may be provided where necessary when you apply for a specific product or service.

We collect and use your personal data to the extent necessary in the framework of our activities and to achieve a high standard of personalised products and services.

We may collect various types of personal data about you, including:

  • personal identification data and contact details (e.g. name, place and date of birth, picture, ID card and passport numbers, postal and electronic address, phone number, sexes, age or signature);
  • identification and authentication data, necessary to the online banking services usage (technical logs, IT tracking, information regarding security and use of terminal, IP address);
  • Tax data (tax ID, tax status, country of residence);
  • Data concerning household composition (e.g. family situation, number of children);
  • Education, training, qualification and employment data (e g. employment, employer's name, remuneration, level of education, professional qualification);
  • Banking, financial data and transactional data (e.g. banking details, credit card number, transactional related data including information on transfers, investor profile, assets values);
  • data relating to your habits and preferences:
    • data which relates to your use of our products and services (banking, financial and transactional data);
    • data from your interactions with us: our office (contact reports), our websites, our apps, our social media pages, meetings, calls, chats, e-mails, interviews, phone conversations;
    • data relating to your lifestyle and consumption habits,
  • phone recording data;
  • image recording data

Only upon obtaining your explicit prior consent, we may collect sensitive data:

  • biometric data (e.g. fingerprint, voice pattern or facial recognition) for identification and security purposes
  • Health data (when necessary and as part of insurance contract conclusion).

Unless we are required by law, we do not collect personal data related to your racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data or data concerning your sex life or sexual orientation.

We only process data relating to criminal convictions and offences if required through a legal obligation.

The data we use about you may be directly collected from you or obtained from other sources in order to verify or enrich our databases, such as:

  • publications/databases made available by official authorities (e.g. the ”registre de commerce et des sociétés”);
  • our service providers/vendors;
  • third parties such as commercial organisms dealing with information to fight against fraud,  and in conformity with data protection legislation;
  • websites/social media pages containing information made public by you and databases made publicly available by third parties.
  • publications/ bases de données rendues accessibles par les autorités officielles (exemple : le registre de commerce et des sociétés) ;
  • nos fournisseurs de services ;
  • tiers tels que les organismes de renseignements commerciaux, de lutte contre la fraude, en conformité avec la réglementation en matière de protection des données ;
  • sites Internet/ pages de réseaux sociaux contenant des informations que vous avez rendues publiques et bases de données rendues publiques par des tiers.

In certain circumstances, we may collect and use personal data of individuals with whom we could have (prospects) or used to have a direct relationship (former members and former services providers/vendors).

We may also collect information about you even if you do not have a direct relationship with us. This may happen for instance when your employer provides us with information about you, or when your contact details are provided by one of our members if you are for example:

  • a family member;
  • a successor or a right holder;
  • a legal representative (power of attorney);
  • a beneficiary of payment transactions made by our member;
  • an ultimate beneficial owner;
  •  a landlord;
  • a company shareholder;
  • a representative of a legal entity (which may be a client or a service provider/vendor);
  • a staff member of one of our service providers/vendors or commercial partners;

a.  To comply with our legal and regulatory obligations

Amongst those obligations we can note:

  • The obligations issued from banking and financial regulations in compliance with which we set up security measures in order to prevent abuse and fraud, we detect transactions which deviate from normal patterns, we record, when necessary, phone calls, chats, e-mails, etc.;
  • Reply to an official request from a duly authorised public or judicial authority;
  • Prevention of money-laundering and financing of terrorism;
  • Compliance with legislation relating to sanctions and embargoes;
  • Fight against tax fraud and fulfilment of tax control and notification obligations;

b. To perform a contract with you or to take steps at your request before entering into a contract

We use your personal data to enter into and perform our contracts with you, including to:

  • manage our products
  • manage our relationship with you;
  • provide you with information regarding our products and services;
  • assist you and answer your requests;
  • evaluate if we can offer you a product or service and under which conditions;

c. To pursue our legitimate interests

We use your personal data in order to develop and deploy our products and services, to improve our risk management and to defend our legal rights, and as well to:

  • keep proof of transactions,
  • perform behavioural and transactional analysis in order to detect fraud;
  • prevent personal injury and damage to goods;
  • ensure the security of persons and property,
  • perform IT management, including infrastructure management (e.g. shared platforms) & business continuity and IT security;
  • establish aggregated statistics, tests and models, for research and development, in order to improve the risk management of AMFIE or in order to improve existing products and services or create new ones;
  • perform member satisfaction and opinion surveys;
  • personalise our product and service offering

d. To respect your choice if we request your consent for specific processing

If we need to carry out further processing for purposes other than those outlined in section 3, we will inform you and, where necessary, obtain your consent.

 

In order to fulfil the aforementioned purposes, we communicate your personal data to:

  • service providers/vendors that perform services on our behalf;
  • financial institutions, banking and commercial partners with which we have a regular relationship;
  • supervisory, financial, taxation, administrative or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law;
  • certain regulated professionals such as lawyers, notaries or auditors.

In case of international transfers originating from the European Economic Area (EEA)

if the European Commission has made a decision on adequacy, recognizing the country a level of data protection equivalent to the one provided by the legislation of the EEA, your personal data will be transferred on this basis;

If the level of protection has not been recognized as equivalent by the European Commission, we rely either on a derogation applicable to the situation (e.g. in case of international payment, the transfer is necessary to the execution of the contract), or on the establishment of appropriate safeguards to ensure the protection of your personal data (standard contractual clauses approved by the European Commission binding corporate rules).

To obtain a copy of theses or to know how to access them, you can send a written request as indicated in Section 9.

We will retain your personal data for the period required in order to comply with applicable laws and regulations, or for the period defined by our operational requirements, such as proper account maintenance, facilitating member relationship management, and responding to legal claims or regulatory requests. For instance, most member information is kept for the entire duration of the contractual relationship and for 10 years after the end of the contractual relationship.

in accordance with applicable regulations, you have the following rights to:

  • Access right: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
  • Rectification right: where you consider that your personal data is inaccurate or incomplete, you can require that such personal data be modified accordingly.
  • Erasing right: you can require the deletion of your personal data, to the extent permitted by law.
  • Right to restriction of the treatment: you can request the restriction of the processing of your personal data.
  • Objection right: you can object to the processing of your personal data, on grounds relating to your particular situation.
    You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
  • Data portability right: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party.
  • Right to withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.

If you wish to exercise the rights listed above, please send a letter or an e-mail to the address set out in section 9. Please include a copy of your valid identity card for identification purposes.

In accordance with applicable regulation, in addition to your rights above, you are also entitled to lodge a complaint with the competent supervisory authority: the “Commission nationale pour la protection des données” (www.cnpd.lu).

We invite you to review the latest version of this notice online www.amfie.org and we will inform you of any material changes through our website or through our other usual communication channels.

If you have any questions relating to our use of your personal data under this Data Protection Notice, please contact us by postal mail AMFIE, 25A, Boulevard Royal  - BP268, L-2012 Luxembourg or by email at amfie@amfie.org.

If you want to know more about cookies, you can read the “Legal notice”  available on our web site (www.amfie.org).

 

Best execution policy

This document constitutes the Best Execution Policy of the Financial Cooperative Association of International Civil Servants, hereafter “AMFIE” or “the Association”. Developed by the authorized management, it describes the investment services provided by AMFIE as well as the channel chosen for the execution of investment instructions in order to obtain the best possible result.

This Policy is based on current regulatory compliance requirements. It will be reviewed regularly to reflect regulatory developments.

The Association’s internal control service regularly verifies compliance with current regulatory requirements and, if necessary, makes recommendations for updating the Policy.

Any order placed by a Member with AMFIE implies the unconditional acceptance of this Best Execution Policy.

The Best Execution Policy applies to all transactions in financial instruments transmitted to AMFIE by its members, all of whom are "retail clients" within the meaning of EU Directive 2014/65/EU also known as the MIFID II Directive.

The financial instruments covered by this policy are as follows:

  • securities;
  • money market instruments;
  • units in collective investment undertakings,
  • options, futures, swaps, forward rate agreements and any other derivative contracts relating to securities, currencies, interest rates or yields or other derivative instruments, financial indices or financial measures that can be settled by physical or cash delivery;
  • options, futures, swaps, forward rate agreements and any other derivative contracts relating to commodities that must be settled in cash or may be settled in cash at the request of one of the parties (other than in the event of default or other event causing termination);
  • options, futures, swaps and any other derivative contracts relating to commodities that can be settled by physical delivery, provided they are traded on a regulated market, MTF or OTF;
  • option contracts, futures contracts, forward contracts, forward exchange contracts and any other derivative contracts relating to commodities that can be settled by physical delivery, not otherwise mentioned in point 6 of Section B of Annex II to the law of 5 April 1993 on the financial sector as subsequently amended (“LSF”) and not intended for commercial purposes, which have the characteristics of other derivative financial instruments, taking into account that, in particular, they are cleared and settled through recognised clearing houses or are subject to regular margin calls;
  • derivatives used to transfer credit risks;
  • financial contracts for differences;
  • option contracts, futures contracts, swaps, forward rate agreements and any other derivative contracts relating to climatic variables, freight rates, emission allowances or inflation rates or other official economic statistics that must be settled in cash or can be settled in cash at the request of one of the parties (other than in the event of default or other termination event), as well as any other derivative contracts relating to assets, rights, obligations, indices and measures, not otherwise mentioned in Section B of Annex II to the LSF, which have the characteristics of other derivative financial instruments, taking into account that, in particular, they are traded on a regulated market, an MTF or an OTF, are cleared and settled through recognised clearing houses or are subject to regular margin calls.

In the context of the management of the liquid assets deposited by members with AMFIE, investment decisions are made. AMFIE does not itself execute orders resulting from investment decisions taken in the context of the discretionary management of the assets deposited with the Association. But it ensures that the best interests of the members are served when orders are transmitted for execution. Buy and sell orders are then transmitted to the various custodians used by AMFIE for execution. A non-exhaustive list of these custodians is given below:

  • Banque de Luxembourg
  • Banque Internationale à Luxembourg S.A.
  • ING Luxembourg
  • Natixis Bank
  • Société Générale Bank & Trust

All the custodians used by AMFIE have their registered office located in Luxembourg and are fully regulated by the Luxembourg supervisory authority (CSSF, Financial Sector Supervisory Commission).

However, when executing orders AMFIE is required to take all sufficient measures to obtain the best possible result for its members, taking into account the price of the financial instrument, the costs related to execution, the speed, the probability of execution and settlement, the size, the nature of the order, or any consideration relating to the execution of the order.

To this end, AMFIE regularly verifies that the entity executing the orders applies the provisions of Article 37-5 of the LSF or equivalent provisions. AMFIE therefore ensures that the above-mentioned custodians apply best execution policies that comply with the legal and regulatory requirements in force.

These policies are also available on the respective websites of these entities, and may also be provided upon request to AMFIE's Secretariat.

AMFIE establishes and publishes annually on its website, for each category of financial instruments, a list of the entities responsible for executing the above-mentioned orders, in particular in terms of trading volume.

AMFIE also publishes on its website an assessment of the quality of execution obtained on each of the platforms it uses and the conclusions it draws from the detailed monitoring of the quality of execution obtained on these platforms.

AMFIE offers its members the possibility of investing in various Financial Instruments as referred to in section B of Annex II to the LFS, e.g. shares, bonds and shares of collective investment undertakings.

In order to execute financial instrument purchase/sale orders for its members, AMFIE has entered into a partnership with Keytrade Bank Luxembourg ("Keytrade"), and with Société Moventum SCA ("Moventum"). In the context of these partnerships with Moventum and Keytrade, AMFIE does not execute its own orders from its members but forwards them to these companies for execution.

However, AMFIE is required to act in the best interests of its members when transmitting their orders for execution to the two companies mentioned above.

To this end, AMFIE ensures that Moventum and Keytrade each have a best execution policy for orders that complies with legal and regulatory obligations in force.

a) Moventum SCA

Moventum's best execution policy for orders is applicable to AMFIE's members for the investment product "AMFUND Savings Plan".

This policy, in English only, is available to AMFIE's members and prospective members upon request to AMFIE's Secretariat.

Any order sent to AMFIE as part of the "Savings Plan" implies outright acceptance of this policy and the policy of Moventum SCA.

b) Keytrade Bank Luxembourg SA

Thanks to the partnership with Keytrade Bank Luxembourg , members can manage their investments directly from their accounts. Members may transmit their purchase /sale orders to AMFIE using the means provided for this purpose and AMFIE then undertakes to transmit these orders as soon as possible to Keytrade Bank Luxembourg for execution. In order to be able to benefit from this service, the Member must open a dedicated individual account with Keytrade Bank Luxembourg in accordance with the procedures defined in the relationship entry documents available through AMFIE or on its website.

AMFIE does not execute orders from its members, but must ensure that their best interests are served when transmitting their orders for execution. To this end, AMFIE regularly verifies that the entity executing the orders, Keytrade Bank Luxembourg, applies the provisions of Article 37-5 of the LSF or equivalent provisions. AMFIE therefore ensures that Keytrade Bank Luxembourg has a best execution policy in line with regulatory obligations. Keytrade Bank Luxembourg's best execution policy applies to AMFIE's members for any order on financial instruments ordered by a member under the tripartite agreement he has signed with Keytrade Bank Luxembourg and AMFIE.

This Policy is available on Keytrade Bank Luxembourg's secure website under Preferences, Knowledge & Experience, Step 2. It can also be consulted from the following links:

English: https://www.keytradebank.lu/secure/doc/mifid/order_execution_policy_LUX_...

French: https://www.keytradebank.lu/secure/doc/mifid/order_execution_policy_LUX_...

This policy is also available to AMFIE's members and prospective members upon request to AMFIE's Secretariat.

Any order that is transmitted to AMFIE pursuant to the above-mentioned tripartite agreement implies the Member's outright acceptance of this policy and the policy of Keytrade Bank Luxembourg for the best execution of orders.

AMFIE reviews its Policy regularly, at least annually, and whenever there is a significant change that affects the Association’s ability to continue to achieve the best possible results for its members. AMFIE reserves the right to amend its Policy at any time it deems appropriate. Any significant change in the Policy shall be notified to the Member.

The fact that the Member sends AMFIE an order for a Financial Instrument implies the express and unconditional acceptance of AMFIE's Policy, that of Keytrade Bank Luxembourg, that of Moventum, and that of its custodians, as applicable at the time the order is placed.

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