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

Our large team of AML / CTF specialists has significant project experience to work with you on pragmatic solutions that are suited to your requirements and to the size of your company.

Adequate internal AML / CTF framework

  • Design or review your AML / CTF policies and procedures;
  • Write or review your AML / CTF risk assessment;
  • Assess your vulnerability and enhance your risk management / oversight mechanism;
  • Review the internal framework of AML / CTF roles and responsibilities and related controls;
  • Design or review the monitoring activities performed by your Compliance Officer / Money Laundering Reporting Officer;
  • Provide your Compliance Officer with constant on-demand support;
  • Review your Management Information System to improve efficiency of decision making;
  • Effectively manage incidents that may create a regulatory or reputational risk.

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Working with third parties

  • Compare target countries' legislation to Luxembourg key AML / CTF legislation and understand gaps and similarities;
  • Conduct specific AML / CTF counterparty due diligence in non AML / CTF Luxembourg equivalent countries;
  • Compare the counterparty's AML / CTF policies and procedures to Luxembourg legal requirements;
  • Provide ongoing due diligence on your active counterparties in non AML / CTF Luxembourg equivalent countries.

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Customer / investor due diligence

  • Provide on-demand compliance support to help you understand and assess specific complex cases;
  • Support you with setting up and executing customers / investors' re-identification plans (including FATCA-relevant aspects);
  • Advise you on setting up a risk assessment and related risk-based approach for your customers / investors;
  • Review investor files in the context of fundmigrations;
  • Perform background checks on individuals and companies;
  • Provide assistance to your customer acceptance committees.

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Transaction and sanction monitoring

  • Support the selection and implementation of an AML / CTF transaction monitoring, sanction / "blacklist" and PEP screening monitoring tool;
  • Define pragmatic behavioural transaction-monitoring tools and reports, based on your customer / investor base and your specific business activity;
  • Optimise and validate the monitoring thresholds;
  • Improve the performance of your automated tools.

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  • Provide annual AML / CTF refresher courses;
  • Design and facilitate tailor-made training solutions;
  • Conduct specific training workshops for Board of Directors or Compliance staff;
  • Provide e-learning programs;
  • Ongoing compliance coaching.

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Audit / due diligence management support

Provide centralised AML reports that can be shared with all the AML / CTF auditors you have to deal with. These reports provide you with:

  • factual comparison of your AML / CTF policies and procedures to key Luxembourg AML / CTF laws and regulations;
  • for an agreed sample of investors, factual comparison of documents on file versus documents required by AML / CTF laws and regulations.

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AML Distributor Due Diligence

  • At the initial set-up of your company's Distributor Due Diligence procedures:
    • We train your Board of Directors, Management and Compliance staff in all AML / CTF matters.
    • We evaluate your current distribution oversight model.
    • We assess the AML / CTF risk of your distribution network and help you prioritise your Due Diligence exercise.
    • We review the AML / CTF clauses of your distribution agreements.
    • We advise you on how best to enter new markets, combining our expertise in Luxembourg AML / CTF regulations with specific knowledge of local markets.
    • We perform country risk assessments.
    • We help you understand local legislation: we compare your target countries' legislation to Luxembourg AML / CTF legislation, determining gaps and similarities.
  • When carrying out initial Distributor Due Diligence:
    • We train and support your internal audit / compliance teams to carry out initial Distributor Due Diligence.
    • We help you understand how to get the right identification documentation for global and foreign distributors (i.e. evidence of existence, reputation checks, company structures).
    • We review the Distributor's AML / CTF procedures, carrying out a gap analysis to ensure compliance with Luxembourg and EU regulations.
    • We make sure that procedures are implemented correctly.
    • We visit your local distributors on site.
    • For distributors working with Luxembourg funds, we write ISAE 3000 Due Diligence Reports on AML / CTF procedures.
  • Ongoing Distributor Due Diligence:
    • We provide ongoing Distributor Due Diligence compliance support.
    • We visit your local distributors with the support of the PwC network, locally.
    • We update our review of your distributors' AML / CTF procedures.
    • We test samples of your investor identification documentation locally at your distributor's.

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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

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

Michael Weis

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

Tel: +352 49 48 48 4153

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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