Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF)

Growing pressure from regulators to comply with Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) rules and regulations associated with intense press coverage of scandals have brought this topic to the top of Management's agenda.

The reputational threat as well as important fines being levied make it crucial to set up and maintain cost-efficient AML/CTF compliance measures and solutions. This is important to the individual market players concerned as well as for Luxembourg's international reputation as a whole.
 

Our Services

In terms of your AML/CTF Compliance Framework, including prevention of the tax crime predicate offense (tax AML), our dedicated team of AML and Tax AML experts are ready to assist you in preparing, responding and emerging stronger in all of the AML related areas within your organisation.  

Who are you? (Please indicate what entity you represent. Appropriate services will appear.)

Prepare - Be compliant
  • Policies and Procedures
  • AML Risk Assessment
    • AML Risk Appetite Framework
    • AML Risk Assessment and Risk-Based Approach
    • Country Risk Assessment
  • AML Risk Management and Governance
  • Assets Due Diligence: scoring and screening
  • Transaction Monitoring and Sanctions Screening
  • Training
Respond - Be effective
  • Gap Analysis
  • Company AML health check
  • Remediation Services
  • Ongoing on-demand Financial Crime / AML Support to Compliance
  • Suspicious Activity and Transaction Reporting Support
  • Investigate and analyse real incidents of money laundering or wider financial crime
Emerge Stronger - Be efficient
  • Digitalisation of customer journey
  • Visualisation reporting (Risk navigator tool)
  • Transaction Monitoring and Screening tools
  • Design and implementation of mitigation plans
  • ISAE 3000 report for compliance with Laws and regulation / Agreed Upon Procedure (AUP) report for specific testing / Internal Audit Support
  • Preparation for regulatory on-site visits
Prepare - Be compliant
  • Policies and Procedures
  • AML Risk Assessment
    • AML Risk Appetite Framework
    • AML Risk Assessment and Risk-Based Approach
    • Country Risk Assessment
  • AML Risk Management and Governance
  • Counterparty Due Diligence
  • Assets Due Diligence: scoring and screening
  • Transaction Monitoring and Sanctions Screening
  • Training
Respond - Be effective
  • Gap Analysis
  • Entity AML health check
  • Remediation Services
  • Ongoing on-demand Financial Crime / AML Support to Compliance
  • Suspicious Activity and Transaction Reporting Support
  • Investigate and analyse real incidents of money laundering or wider financial crime
Emerge Stronger - Be efficient
  • Digitalisation of customer journey
  • Visualisation reporting (Risk navigator tool)
  • Transaction Monitoring and Screening tools: improvement of efficiency by defining, reviewing and setting appropriate scenario
  • Design and implementation of mitigation plans
  • ISAE 3000 report for compliance with Laws and regulation / Agreed Upon Procedure (AUP) report for specific testing / Internal Audit Support
  • Preparation for regulatory on-site visits
Prepare - Be compliant
  • Policies and Procedures
  • AML Risk Assessment
    • AML Risk Appetite Framework
    • AML Risk Assessment and Risk-Based Approach
    • Country Risk Assessment
  • AML Risk Management and Governance
  • Counterparty Due Diligence
  • Assets Due Diligence: scoring and screening
  • Transaction Monitoring and Sanctions Screening
  • Training
Respond - Be effective
  • Gap Analysis
  • Company AML health check
  • Remediation Services
  • Ongoing on-demand Financial Crime / AML Support to Compliance
  • Suspicious Activity and Transaction Reporting Support
  • Investigate and analyse real incidents of money laundering or wider financial crime
Emerge Stronger - Be efficient
  • Digitalisation of customer journey
  • Visualisation reporting (Risk navigator tool)
  • Transaction Monitoring and Screening tools
  • Design and implementation of mitigation plans
  • ISAE 3000 report for compliance with Laws and regulation / Agreed Upon Procedure (AUP) report for specific testing / Internal Audit Support
  • Preparation for regulatory on-site visits
Prepare - Be compliant
  • Policies and Procedures
  • AML Risk Assessment
    • AML Risk Appetite Framework
    • AML Risk Assessment and Risk-Based Approach
    • Country Risk Assessment
  • AML Risk Management and Governance
  • Counterparty Due Diligence
  • Assets Due Diligence: scoring and screening
  • Transaction Monitoring and Sanctions Screening
  • Training
Respond - Be effective
  • Gap Analysis
  • Entity AML health check
  • Remediation Services
  • Ongoing on-demand Financial Crime / AML Support to Compliance
  • Suspicious Activity and Transaction Reporting Support
  • Investigate and analyse real incidents of money laundering or wider financial crime
Emerge Stronger - Be efficient
  • Visualisation reporting (Risk navigator tool)
  • Design and implementation of mitigation plans
  • ISAE 3000 report for compliance with Laws and regulation / Agreed Upon Procedure (AUP) report for specific testing / Internal Audit Support
  • Preparation for regulatory on-site visits
Prepare - Be compliant
  • Policies and Procedures
  • AML Risk Assessment
    • AML Risk Appetite Framework
    • AML Risk Assessment and Risk-Based Approach
    • Country Risk Assessment
  • AML Risk Management and Governance
  • Transaction Monitoring and Sanctions Screening
  • Training
Respond - Be effective
  • Gap Analysis
  • Company AML health check
  • Remediation Services
  • Ongoing on-demand Financial Crime / AML Support to Compliance
  • Suspicious Activity and Transaction Reporting Support
  • Investigate and analyse real incidents of money laundering or wider financial crime
Emerge Stronger - Be efficient
  • Digitalisation of customer journey
  • Visualisation reporting (Risk navigator tool)
  • Transaction Monitoring and Screening tools
  • Design and implementation of mitigation plans
  • ISAE 3000 report for compliance with Laws and regulation / Agreed Upon Procedure (AUP) report for specific testing / Internal Audit Support
  • Preparation for regulatory on-site visits
Prepare - Be compliant
  • Policies and Procedures
  • AML Risk Assessment
    • AML Risk Appetite Framework
    • AML Risk Assessment and Risk-Based Approach
    • Country Risk Assessment
  • AML Risk Management and Governance
  • Transaction Monitoring and Sanctions Screening
  • Training
Respond - Be effective
  • Gap Analysis
  • Company AML health check
  • Remediation Services
  • Ongoing on-demand Financial Crime / AML Support to Compliance
  • Suspicious Activity and Transaction Reporting Support
  • Investigate and analyse real incidents of money laundering or wider financial crime
Emerge Stronger - Be efficient
  • Digitalisation of customer journey
  • Visualisation reporting (Risk navigator tool)
  • Transaction Monitoring and Screening tools
  • Design and implementation of mitigation plans
  • ISAE 3000 report for compliance with Laws and regulation / Agreed Upon Procedure (AUP) report for specific testing / Internal Audit Support
  • Preparation for regulatory on-site visits
Prepare - Be compliant
  • Policies and Procedures
  • AML Risk Assessment
    • AML Risk Appetite Framework
    • AML Risk Assessment and Risk-Based Approach
    • Country Risk Assessment
  • AML Risk Management and Governance
  • Transaction Monitoring and Sanctions Screening
  • Training
Respond - Be effective
  • Gap Analysis
  • Company AML health check
  • Remediation Services
  • Ongoing on-demand Financial Crime / AML Support to Compliance
  • Suspicious Activity and Transaction Reporting Support
  • Investigate and analyse real incidents of money laundering or wider financial crime
Emerge Stronger - Be efficient
  • Digitalisation of customer journey
  • Visualisation reporting (Risk navigator tool)
  • Transaction Monitoring and Screening tools
  • Design and implementation of mitigation plans
  • ISAE 3000 report for compliance with Laws and regulation / Agreed Upon Procedure (AUP) report for specific testing / Internal Audit Support
  • Preparation for regulatory on-site visits
Prepare - Be compliant
  • Policies and Procedures
  • AML Risk Assessment
    • AML Risk Appetite Framework
    • AML Risk Assessment and Risk-Based Approach
    • Country Risk Assessment
  • AML Risk Management and Governance
  • Counterparty Due Diligence
  • Assets Due Diligence: scoring and screening
  • Transaction Monitoring and Sanctions Screening
  • Training
Respond - Be effective
  • Gap Analysis
  • Entity AML health check
  • Remediation Services
  • Ongoing on-demand Financial Crime / AML Support to Compliance
  • Suspicious Activity and Transaction Reporting Support
  • Investigate and analyse real incidents of money laundering or wider financial crime
Emerge Stronger - Be efficient
  • Digitalisation of customer journey
  • Visualisation reporting (Risk navigator tool)
  • Transaction Monitoring and Screening tools: improvement of efficiency by defining, reviewing and setting appropriate scenario
  • Design and implementation of mitigation plans
  • ISAE 3000 report for compliance with Laws and regulation / Agreed Upon Procedure (AUP) report for specific testing / Internal Audit Support
  • Preparation for regulatory on-site visits
Prepare - Be compliant
  • Policies and Procedures
  • AML Risk Assessment
    • AML Risk Appetite Framework
    • AML Risk Assessment and Risk-Based Approach
    • Country Risk Assessment
  • AML Risk Management and Governance
  • Counterparty Due Diligence
  • Assets Due Diligence: scoring and screening
  • Transaction Monitoring and Sanctions Screening
  • Training
Respond - Be effective
  • Gap Analysis
  • Company AML health check
  • Remediation Services
  • Ongoing on-demand Financial Crime / AML Support to Compliance
  • Suspicious Activity and Transaction Reporting Support
  • Investigate and analyse real incidents of money laundering or wider financial crime
Emerge Stronger - Be efficient
  • Digitalisation of customer journey
  • Visualisation reporting (Risk navigator tool)
  • Transaction Monitoring and Screening tools
  • Design and implementation of mitigation plans
  • ISAE 3000 report for compliance with Laws and regulation / Agreed Upon Procedure (AUP) report for specific testing / Internal Audit Support
  • Preparation for regulatory on-site visits

Respond - Be effective

Gap Analysis

The fight against ML and TF is global, and as it is constantly changing and developing rapidly, countries are obliged to amend their laws and regulations in line with global standards and new threats and vulnerabilities surrounding this topic. Keeping up with policy changes and amendments might seem daunting. More so when you are a global corporation with subsidiaries in several countries, and you are required to compare AML laws in various jurisdictions with one another on a continuous basis.  

Your issues: 

  • You require a summary of the impact of a new law or regulatory amendment; 

  • You require assistance with the interpretation of a new law of regulatory amendment; 

  • You are struggling to understand the difference between the Luxembourg legislative requirements and those requirements in jurisdictions in which subsidiaries are based;

  • You are struggling to understand requirements from equivalent or not equivalent countries;  

  • You are unable to ascertain whether a group level policy or procedure would be sufficient to protect you under the Luxembourgish regulations;  

  • You require assistance in creating an action plan or swift actions that are recommended in order to comply with any new laws of amendments; 

  • You require assistance to update your procedures to take into account CSSF circulars 17/650 and 20/744 on the prevention of tax fraud (for CSSF regulated entities).

How we can help :

PwC can support you by : 

  • Comparing target countries' legislation to key Luxembourg AML/CTF legislation and assist you in understanding any gaps and similarities;

  • Performing a factual comparison of your AML/CTF policies and procedures to key Luxembourg AML/CTF laws and regulations; 

  • For an agreed sample of clients or investors, perform a factual comparison of documents on file versus documents required by AML/CTF laws and regulations;

  • Assisting you to interpret regulatory requirements;

  • Provide workshops and training on the main provisions of new and existing regulatory requirements and the key impacts to the organisation;

  • Conduct a gap analysis to assess gaps in the current processes against those required by existing and new legislation;

  • Designing plans and structures for onboarding of new regulatory requirements; 

  • Assess the workload of new requirements (e.g. remediation, transaction monitoring system updates, etc.);

  • Perform an AML/CTF Quality Assessment/Health Check: 

    • We can support you in conducting AML Quality Assessments or a Health Check. We can review your AML/CTF compliance framework analysis whether all key policies and procedures, documents, systems and processes are in place that together form your AML/CTF internal control framework. A Health Check will provide you with the comfort that you covered all the bases or provide you with a list of gaps and action items of points that are not sufficiently covered to achieve AML/CTF compliance. The nature of the Health Check will be tailored to your organisational set up and will be industry and sector specific. The Health Checks are carried out by our AML/CTF subject matter experts who have a specific industry and sector focus. 

Company AML health check

Your Company is subject to many reviews by the internal and external auditor and as management you may like the comfort that all key aspects of your AML/CTF governance framework cover the regulatory requirements. We can provide you with an independent view by verifying key points and providing recommendations to you. 

Review of policies and key governance framework documents:

  • Gap analysis of AML/CFT policies and procedures to ensure that Luxembourg AML/CFT most recent Laws and Regulations are covered;

  • Review of the AML/CFT Risk Appetite Framework including Key Performance Indicators;

  • Review of the AML/CFT Risk Assessment methodology; and

  • Review Country Risk Assessment methodology and a sample of country risk analysis.

Processes and Sampling:

  • Observation and analysis of the process used for AML/CFT sanction screening and the analysis of screening hits with some sample testing; 

  • Observation and analysis of the suspicious transactions and suspicious activity screening process and systems;

  • Sample testing of customer and other counterparty KYC files to test completeness and compliance; 

  • Corroborating that AML CSSF Questionnaire was appropriately completed by tracing back answers to source data on a sample basis;

  •  

    For investment funds and vehicles and investment fund managers, high level gap analysis of AML/CTF distribution oversight in relation initial and ongoing distributor and intermediary due diligence, with some sample testing;

  • For investment funds and vehicles and investment fund managers, high level gap analysis of AML/CTF Transfer Agent oversight plan and Transfer Agent oversight measures, based on recent Transfer Agent oversight exercise (sample); and

  •  

    For investment funds and vehicles and investment fund managers, high level gap analysis of AML/CTF Investment Manager oversight in relation to performing AML/CTF on assets, with some sample testing.

     

Remediation Services

A “Plug&Play” service tailored to your needs

Know Your Customer (KYC) is the foundation of Customer Due Diligence (CDD) that concerns the precise identification of customers and business partners. 

A robust KYC program:

  • Supports an organisation wide compliance with laws and regulations, and mitigates Financial Crime risks;

  • Prevents financial institutions from being used, intentionally or unintentionally, by criminal elements for Financial Crime activities;

  • Helps financial institutions to better understand their customers and their financial dealings, which enables prudent risk management. 

Customer or business remediations are an essential element of any organisations AML/CTF Compliance programme, and can be a frustrating and time-consuming process. Remediations can be triggered at any time, due to a trigger event such as a change in the law or in your organisation’s risk appetite or because you face backlogs in your on-going review of files. 

PwC utilises the power of our synergistic team by bringing together a mix of subject matter experts and technology capabilities to help our clients diligently meet their CDD/KYC obligations in an easy and innovative way. Conducting a thorough and timely data cleanse to remove data duplicates and inconsistencies is also a key element. We design CDD/KYC specific solutions to offer wide-ranging support and defense against Financial Crimes, while reducing your number of CDD/KYC issues, in particular when it comes to remediating your client populations. 

Your issues: 

  • Targets: Unrealistic targets and deadlines to complete the upload of files result in a missed opportunity to conduct a detailed end-to-end file analysis, obtain additional data and advise key stakeholders;
  • Resources: Lack of experienced and sufficient staff can result in missing regulatory deadlines or loss of capability to handle the volume of data. The effort to render a file complete is underestimated and relevant risks are neither identified nor mitigated;
  • Knowledge and expertise: You are short staffed and require subject matter experts’ knowledge and expertise on a temporary basis without a full-time hire;
  • Platform and tools: AML/CTF systems that are unable to handle growing volume of data and cope up with changing regulatory requirements. It may lead to ineffectiveness and inefficiencies while identifying money laundering risks and combatting financial crime.

How we can help: 

Our flexible offering of KYC services provides you with several options to manage and/or tailor our KYC services for your specific needs. It leverages on the power of our synergistic team which combines subject matter experts (SMEs) and technology capabilities to help you diligently meet your KYC obligations in the most efficient and innovative way. 

PwC can support you by: 

  • Providing on-demand remediation support to help you to clear backlog of customer or other business relationship KYC files including a tax high level or deep dive review, perform periodic reviews or reviews based on trigger events, and assist you to understand and assess specific complex cases: 

    • Tailored KYC Services: 

      • Full Managed Services

        • Full outsourcing of your KYC activities to us, including having access to a platform where you can access and archive your KYC data.

      • Hybrid Managed Services with a partial co-sourcing of your KYC activities based on the following solutions:

        • tailored KYC services: onsite with the use of our tools and platform; 

        • whether onsite or offsite with the use of your tools and platform; 

        • representing only a part of a process (e.g. quality works).

    • Project management support upon request.

  • In instances where you have a backlog of clients or counterparties to on-board, or periodically refresh, PwC can assist you with the day-to-day business as usual tasks required in order to successfully onboard or refresh clients or counterparties (including distributors for investment funds and vehicles and investment fund managers); 

  • Performing an As-Is assessments;

  • Reviewing current state gaps to determine optimal future state along with pre-determined milestones for execution and completion of your KYC files; 

  • Performing a back-book review of existing customer files and identifying a number of areas for remediation; reviewing client files following changes your organisation's risk appetite resulting in re-classification of customer risk ratings we can leverage on customer files review to assess the files from an AML/CTF, Tax AML but also DAC 6 perspective; 

  • Identifying and understanding root causes of backlog and areas of improvement;  

  • Conducting a thorough and timely data cleanse to remove data duplicates and contradictions; 

  • Performing essential KYC checks on your client population to ensure compliance with regulations, customer due diligence and enhanced due diligence requirements and best practices; and analysing your name screening tool and results to ensure accurate alert detection;

  • PwC can further support with setting up and executing customers / investors' re-identification plans (including tax relevant matters); and reviewing investor files in the context of fund migrations for investment funds and vehicles and investment fund managers. We can also assist you in preparing correspondences and can manage the follow up process on your behalf. 

Ongoing on-demand Financial Crime / AML Support to Compliance

SME (Subject Matter Expert) support for your RC (“Responsable du Contrôle du respect des obligations professionnelles”)

PwC can provide you with Luxembourg AML/CTF SME support for your RC on an ad-hoc and ongoing basis. We can provide on demand support with the required on-site SME support, working on your systems at your premises to ensure high quality delivery. We provide ongoing SME support to address and co-create specific technical requirements. We can further provide regulatory analysis or be your sounding board in complex regulatory situations.

AML Hotline 

We can set up a dedicated technical hotline with access to PwC SMEs, offering on demand technical assistance as and when necessary, to advise you in understanding any new and specific matters related to AML/CTF regulatory requirements as defined by applicable laws and regulations in Luxembourg. 

PwC can assist you by:

  • Facilitating your understanding of AML/CTF prudential and regulatory questions on recent changes;

  • Discussing AML/CTF market best practices;

  • Discussing regulatory AML/CTF updates;

  • Answering specific AML/CTF-related questions that you might have. 

Suspicious Activity and Transaction Reporting Support

Under the Luxembourg AML law, entities are obliged to report all suspicious client activity to the FIU (Financial Intelligence Unit or CRF – Cellule de Renseignement Financier in Luxembourg) in the form of a Suspicious Activity Report (SAR)/Suspicious Transaction Report (STR). A SAR/STR is to be reported whenever there is a suspected case of money laundering or fraud. These reports are tools to help monitor any activity within finance-related industries that is deemed out of the ordinary, a precursor of illegal activity, or might threaten public safety. Failure to do so could result in a regulatory fine, or a very real possibility that your organisation could be used to launder illicit funds without detection. 

Your issues:

  • You are unsure whether a transaction is suspicious or not; 

  • You require direction regarding ‘red flags’ applicable to your organisation;

  • You have a large backlog of alerts that need to be investigated, and you lack the resource and expertise to do so; 

  • You fear that suspicious transactions have previously gone unreported. 

How we can help: 

PwC can support you by:

  • Assisting in identifying and analyzing potentially suspicious activities;

  • Assisting you in filing a Suspicious Activity Report (SAR)/Suspicious Transaction Report (STR);

  • Assisting you in clearing your backlog of suspicious activity alerts triggered by employees and or transaction monitoring systems;

  • Training staff on how to identify suspicious activities and transactions and the reporting process; and

  • Creating or amending existing policies and procedures regarding the reporting of a SAR/STR to the FIU. 

Investigate and analyse real incidents of money laundering or wider financial crime

Our detection and investigation specialists work with our experts in forensic technology solutions, combining extensive practical experience, formal training and a wide range of tools and techniques to detect and investigate Money Laundering (ML) and wider Financial Crime (FC).  We provide a robust investigative approach to assist our clients in establishing the facts and making recoveries. We can identify the root causes of discrepancies, allegations and other ML irregularities by assembling and securing evidence. 

Your issues: 

  • You detected a ML incident and a qualified response is required.

  • You have suffered a ML incident and need an estimation of reputational or material damages.

  • You raised suspicion of ML or wider FC, that is material for the business operations and further investigation is needed.

  • Internal audit reports indicate discrepancies/concerns as to potential ML or wider FC.

  • Tip-offs surrounding possible ML from whistle-blower hotline have been received.

How we can help: 

PwC AML and Forensic Services team comprises of diverse experts and trained professionals in various areas: AML/CTF, legal, financial, accounting, computer science, data analytics compliance and other.

The value we deliver: 

  • Greater agility and faster access to key facts by applying data-driven approaches and tools to mine documents and records;

  • Depth of investigator experience as it relates to ML and FC;

  • Access to AML, technology, accounting and tax expertise; and

  • Insight into current developments in AML/CTF, regulation and FC. 

We solve important problems for our clients by: 

  • Investigating: 

Establish the key facts of any given situation and deliver findings and evidence in a manner that allows the implementation of recovery and remedial action. We help you to manage the interests of third parties, whether they are customers or suppliers, regulators or law enforcement agencies.

  • Analysing: 

Understand the facts in context. By drawing upon our deep technical and industry knowledge we are able to quantify potential issues, help you consider the wider implications of any ML or FC and provide practical support and advice in developing a strategic response.

  • Resolving: 

Any stakeholder to the business may have an interest in the outcome of an investigation. Whether dealing with law enforcement agencies, regulators or other parties we are able to assist in managing your position and the preparation of your case. Should remediation be required, we bring expertise from across our firm to assist in changing and strengthening processes and controls.

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In an increasingly complex world of new regulations, demonstrating robust oversight of all your delegates is paramount. Identifying the highest risks and applying the latest regulations, ensuring you have the appropriate resources to track the rules and assess the due diligence. PwC can help you identifying and mitigating these risks.

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Contact us

Michael Weis

Partner, Advisory, AML and Financial Crime leader, PwC Luxembourg

Tel: +352 49 48 48 4153

Roxane Haas

Partner, Audit, specialised in AML for the Banking industry, PwC Luxembourg

Tel: +352 49 48 48 2451

Birgit Goldak

Partner, Risk Assurance, specialised in AML for the Asset Wealth Management industry, PwC Luxembourg

Tel: +352 49 48 48 5687

Murielle Filipucci

Partner, Tax, specialised in AML and prevention of tax crimes, PwC Luxembourg

Tel: +352 49 48 48 3118

Pierre Kirsch

Partner, Tax, specialised in AML and prevention of tax crimes, PwC Luxembourg

Tel: +352 49 48 48 4031

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