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

Prepare - Be compliant

Policies and Procedures

Policies and procedures should be designed in a way that ensures compliance with the Laws and Regulation applicable in Luxembourg (i.e. Laws and Grand-Ducal, Ministerial, CSSF regulations and circulars). These must be reviewed at least annually in order to ensure that they remain accurate and include any change in ML/TF Law and Regulations and/or changes in the entity’s business activity. Whilst policies establish the ruling principles and minimum standards for ML/TF, operating procedures specify the control framework adopted by business on a day-to-day basis.


Your issues:

  • Your policy is outdated and or not customised to Luxembourg laws and regulations; 
  • A change in regulation has resulted in a need to amend your existing policies and procedures. These policy changes are being interpreted differently by business lines; 
  • (TAX AML) Your policies and procedures have not been adapted to include tax crimes as predicate offenses (aggravated tax fraud and tax swindle) further to the Law dated 23 December 2016 and CSSF circulars 17/650 and 20/744;
  • (TAX AML) For investment funds and vehicles and investment fund managers, your policies and procedures have not been adapted to include the indicators of potential tax crimes set-out in CSSF circular 20/744 regarding collective investment activities;
  • Your Head Office modified the applicable policies and/or procedures; and those changes are unclear, not communicated in time and/or is of a lower standard than what is required in Luxembourg;
  • You are concerned about an inspection of your policies and procedures by Internal Audit, External Audit or the regulator; 
  • You are concerned about the appropriate coverage of all parts of your business by your existing policies and procedures framework. 

How we can help:

  • Reviewing your existing policies, procedures and controls on an annual basis to ensure that they are compliant with the applicable regulations, in line with international best practices and fit-for-purpose for your specific industry, and if not, designing new policies and procedures that are compliant;

  • Performing a gap analysis between your existing procedures and new laws or amendments and assess the concrete impacts (e.g. client remediations, changes to your systems and processes,
    changes to your Transaction Monitoring system) and assessing the workload expected to address the gaps identified. 

AML Risk Assessment

AML Risk appetite framework

Define the risk your organization is willing to accept

The identification of Money Laundering and Terrorist Financing (ML/TF) risk exposure as part of its strategy will enable organisations to determine their risk acceptance/tolerance and will further enable them to design in advance mitigating actions allowing the various lines of business to operate within those risk limits.

ML/TF risk prevention starts with the definition of your organisation acceptable risk, as described in the strategy and risk appetite approved by your organisation’s supervisory body.

The Luxembourg AML/CTF regulation requires the implementation of a clear AML/CTF risk appetite and strategy, in line with the principle of sound and prudent management and aligned with the organisation's goals in terms of AML/CTF prevention. This AML/CTF risk appetite must be discussed and approved by the Board of Directors in a written, detailed document, including but not limited to the types of clients, geographies, products and services the organisation wishes to cover (or avoid) and the resources and tools required to adequately control the risk. It should include Key Risk Indicators (KRI) and Key Performance Indicators (KPI) that help the organization monitor whether the established risk appetite is respected.

Your issues: 

  • Your risk appetite has not been formalised or documented;
  • You need to design KRI and KPI to monitor the limits agreed by the board of directors, including Key Tax risks indicators;
  • You disagree on the definition of “client” and appropriate risk rating calculations, resulting in a risk appetite lacking clarity;
  • You are unable to adequately ascertain your ML/TF risk exposure; 
  • You need assistance in designing an action plan on how to mitigate the risks presented within your risk appetite.

How we can help: 

PwC can support you to update your risk appetite framework annually – driving discussions among various business units, compliance and Management by: 

  • Identifying the AML risk exposure your strategy represents; 

  • Supporting the quantification and definition of the risk limits (KPIs); 

  • Designing criteria for a risk appetite for client onboarding and trigger reviews based on time and events, and subsequently, a practical and balanced client risk rating; and

  • Consolidating the risk acceptance approach from stakeholders for informed decision making/to assist the Board of directors.

AML Risk Assessment and Risk-Based Approach

The obligation to perform a risk assessment is a legal requirement according to article 2.2 of Law of 12 November 2004, and CSSF Circular 11/519 and 11/529  (for CSSF regulated entities). It is a way for organisations to assess and monitor their risks and keep them under the limits accepted /risk tolerance as well as to assist them in implementing internal control measures to mitigate these risks. CSSF Circular 17/661, detailing the Risk Factor Joint Guidelines from the EBA, and CSSF circular 18/702 (specifically for private banks), describe the risks that entities must take into consideration when assessing their risk exposure insofar as it relates to their customers, geographical areas, products and services and distribution channels. 

Organisations are required to adapt their risk scenarios (including risks of tax crimes) on an ad-hoc basis in line with their businesses and activities. 

Your issues: 

  • You do not have an up-to-date risk assessment or your existing risk assessment is not sufficient for your needs;

  • (TAX AML) You do not have an up-to-date risk assessment taking into account the prevention of tax crimes; 

  • You require assistance in implementing internal control measures to mitigate risks identified in your risk assessment;

  • You require assistance with the drafting and or implementation of a risk-based approach demonstrating your understanding of the risks applicable to your organisation/institution;

  • You want to be certain that your risk assessment covers all risks inherent and residual of all business areas and can be easily maintained. 

How we can help:

  • Assisting you with updating your risk assessment with a tool that can be tailored to your specific set up; which calculates inherent and residual risk. This is to ensure that you are adequately identifying the inherent risks applicable to your organization and quantifying the customer, product, service, geographical and distribution channel risks;

  • We can support you in reviewing your quantitative and qualitative methodology and the way you calculate your inherent and residual risks;

  • We will further support you on your annual assessment of mitigating factors and annual reports submitted to governance or regulator.

Country Risk Assessment 

According to the Wolfsberg group, "the term 'country risk' has typically referred to the additional risk created by investing in, or lending cross border to, a foreign country in the context of credit facilities. With the introduction of the Risk-Based Approach as the overriding principle in the fight against financial crime, country factors (amongst others) were identified as being relevant to assessing the financial crime risk of the customer. These country factors could include a customer's domicile or country of incorporation, center of activity or other nexus, such as country of tax residency. Therefore, when assessing a customer’s risk profile, financial institutions need to consider not only the financial crime risk related to the customer and the customer’s source of wealth, but also the legal frameworks and their effectiveness, as well as the political environment in the countries where the customer is active". 

Your issues: 

  • You require assistance in designing a methodology to assess the risk afferent to each country (including from a tax transparency perspective); 

  • You require clarity as to the sources to be considered when developing a country risk assessment methodology; 

  • You require a refresh of existing data sources; 

  • You need a specific country risk assessment. 

How we can help: 

  • We can assist you in performing a country risk assessment - identifying, assessing and helping you to understand the ML and TF risks applicable to the country in question; 

  • We can provide you with a methodology (tailored to your business) to perform a country risk assessment.

Risk Management and Governance

Assess Risk Management

The fight against ML/CT is carried out by the Three Lines of Defence. The performance/management of the AML/CTF framework is in turn reported to the management and the internal control/supervisory bodies.

Establishing an adequate reporting line and a systematic oversight function with stakeholders, branches and subsidiaries is crucial for the alignment of the business strategy, risk tolerance and the residual risk/monitoring actions. The amount of information, documentation and stakeholders involved in the reporting process makes it essential to ensure your organisation has a systematic reporting line and a strong oversight function. 

Your issues: 

  • Your internal control environment is not properly documented;

  • (TAX AML) Your internal control environment does not include controls on the tax crime indicators set-out in CSSF circulars 17/650 and 20/744 (for CSSF regulated entities); 

  • Your organisation does not have documented roles and responsibilities; 

  • Your first line is performing second line functions or vice versa;

  • You are unable to adequately oversee your various branches or subsidiaries and have experienced a breakdown in reporting with these business units. 

  • Specifically for investment funds and vehicles and investment fund managers, you are willing to implement or confirm the implementation of the oversight mechanism in line with the CSSF Circular 18/698.

How we can help: 

  • Assist you in defining and improving your control and prevention framework to fight Financial Crime within your organisation; 

  • Support and assist control functions in implementing and rolling out Financial Crime Risk Management; 

  • Review and make recommendations to the existing governance structure;

  • Reviewing your existing roles and responsibilities to ensure the definition of adequate tasks and reporting lines and a systematic oversight function;  

  • Review and make recommendations to the current governance reporting line processes, with a top down and transversal direction.
  • Visualise the information reported in a dashboard;

  • Support you in the oversight function with branches and subsidiaries; 

  • Assist the compliance function with specific requests, providing outsourcing services of our expert team; 

  • Review your MLRO Report and challenge its content; 

  • Review your CSSF Questionnaire; 

  • Assist in the completion of the CSSF AML Questionnaire via a data driven approach; 

  • Specifically for investment funds and vehicles and investment fund managers:
    • Provide dedicated and tailored training for Transfer Agents, Management Companies and Board of Directors on the AML/CTF requirements of CSSF Circular 18/698 – for Asset and Wealth Management, Real Estate and Private Equity; 
    • Provide advice on AML/CTF steps in relation to assets (UCITS, Real Estate, Private Equity and Infrastructure); 
    • Review/Advise you on your Transfer Agent Oversight internal controls and communication flow; 
    • Review the reporting between Transfer Agent/Management Company and Board of Directors; 
    • Review distributor risk, buyer and seller (for Alternatives) and Asset Risk Assessment methodology; and
    • Review oversight policy for Delegates, including Distributors and Intermediaries. 

Counterparty Due Diligence

AML/CTF counterparty due diligence is mandatory in terms of the Luxembourg laws and regulations, as soon as you are willing to rely on this counterparty for AML/CTF purposes.

In particular for investment funds and vehicles and investment fund managers and the distributors due diligence, you are finding it increasingly difficult to keep up with the regulatory amendments, ensure your AML/CTF due diligence files are up to date, and may lack the skills and expertise to oversee distributors effectively.

Your issues: 

  • You are unsure whether your internal framework complies with the requirements of the current Luxembourg AML / CTF applicable laws;

  • Specifically for investment funds and vehicles and investment fund managers, you are willing to implement or confirm the implementation of the oversight mechanism in line with the CSSF Circular 18/698.
  • You are in need of updated distributor your due diligence and distribution oversight policies and procedures.

  • (TAX AML) The distribution oversight policies and procedures have not been adapted to include the indicators of potential tax crimes set-out in CSSF circular 20/744 regarding collective investment activities;

  • You have no first line function on site, and as such you have nobody to perform first line functions including remediating distributor files;

  • You require training on distributor due diligence and do not have the capabilities to offer this training in-house. 

How we can help: 

Initial and ongoing AML/CTF and Business Due Diligence on counterparties

PwC can assist you with the initial set-up or review of the AML/CTF and business due diligence of counterparties procedures by:

  1. Training the relevant staff

  2. Reviewing the current oversight model and policy

  3. Reviewing the risk-based approach and multi annual due diligence plan

  4. Reviewing the AML / CTF clauses of the agreements with the counterparties

  5. Performing country risk assessments

  6. Visiting local counterparties on site

  7. Supporting internal audit and compliance teams as they tackle the topic of the oversight

Specifically for investment funds and vehicles and investment fund managers, initial AML/CTF and Business Due Diligence of Delegates and Distribution Intermediaries (Distribution/Portfolio Management /Transfer Agent/Fund Accounting)

PwC can assist you with the initial set-up or review of the AML/CTF and business due diligence of distributors and distribution intermediaries’ procedures by:

  1. Reviewing the risk-based approach and multi annual due diligence plan
  2. Performing country risk assessments.

PwC can further assist you when carrying out initial AML/CTF and business due diligence of distributors and distribution intermediaries by:

  1. Helping you perform the appropriate initial due diligence and understand how to get the right identification documentation for global foreign distributors

Specifically for investment funds and vehicles and investment fund managers, ongoing AML and Business Due Diligence of Delegates and Distribution Intermediaries (Distribution /Portfolio Management /Transfer Agent/Fund Accounting)

PwC can assist you in performing ongoing AML/CTF and business due diligence of distributors and distribution intermediaries by:

  1. Providing ongoing distribution due diligence subject matter expert support

Assets Due Diligence / Scoring and screening

In the framework of investment business, the CSSF regulation requires the professionals shall carry out an analysis of the ML/TF risk posed by the investment and take appropriate due diligence measures.

We can support you with the design of appropriate procedures for the scoring and screening of assets taylored to your business.

Specifically for investment funds and vehicles and investment fund managers, the model used often includes several parties and decision makers. We can support you with a pre-designed tool and scoring model that meets Luxembourg AML/CTF legal and regulatory requirements to help navigate the complex area to be sure that you are compliant. We can also review the scoring model in place in your organisation.

Your issues: 

  • You are not sure whether the AML risk assessment and AML controls are compliant; 

  • You are wondering how CSSF Circulars 17/650 and 20/744, where relevant will affect you; 

  • Your risk and control framework around assets are not complete; 
  • Your processes and risk scoring model are unclear. 

How we can help: 

PwC can support you by: 

  • Formalising your asset scoring model; 

  • Assisting you with the implementation and customisation of the tool, including methodology; 

  • Review your existing scoring model.

Transaction Monitoring and Sanctions Screening

Several legal requirements and best practices guidelines have identified certain risk criteria that organisations should target in order to prevent and detect any suspicious activity or criminal offences. In line with FATF guidance, monitoring should be carried out on a continuous basis or triggered by specific transactions. Electronic systems aren’t necessarily required, although for some types of activity, where large volumes of transactions occur on a regular basis, automated systems may be the only realistic method of monitoring transactions. Where automated systems are used, organisations should understand their operating rules, verify their integrity on a regular basis and check that they address the identified ML/TF risks. Furthermore, entities are legally required to screen their clients, investors and all other related parties against the relevant sanction / "blacklists" . 

Your issues: 

  • You are unsure of whether a transaction is suspicious (including from an AML tax perspective) or not and how to report a suspicious transaction to the regulator; 

  • You have a backlog of suspicious transaction and or sanctions alerts and not enough in house resources to clear these alerts; 

  • Your transaction monitoring and sanctions screening escalation processes are undefined and as such staff are unsure of what to do once the investigation is completed. 

How we can help: 

  • Transaction monitoring data and sanctions screening quality/health-check: 

Possible issues related to the data output by automated monitoring tools are not related to how the tool is parameterized, but rather to the quality of the data gathered in the systems. Therefore, data inputted in the tool should be periodically stress tested to ensure its quality and integrity. Considering the activities carried out by your organization, PwC will define the information required for transaction monitoring purposes and will launch a pre-selected field file to check the quality/health of the data exported from tool in terms of completeness, accuracy and integrity. 

PwC will assess the quality/health of the data used for transaction monitoring, but also for data reported to the authorities as well as on the periodical internal Key Performance Indicators used for reporting to management, the board of directors and or other stakeholders; 

If remediation actions are needed, PwC will help you to define an action plan to mitigate data issues and put at your disposal an experienced team that will support you to carry out the required remediation action. 

  • Design and implement control frameworks and processes to aid efficiency;

  • Assess current procedures, processes and technologies used to comply with Luxembourg regulations surrounding sanctions and suspicious transaction reporting;

  • Provide assistance in clearing alerts from your backlog by providing a team of analysts and Subject Matter Experts support when required;

  • Provide training to increase awareness of potentially suspicious transactions and activities and how to identify them during the ordinary course of business.

Training

Your issues: 

  • You are overwhelmed by the rapid changes of regulation and not allocating enough time to develop your own training material to manage this risk; 
  • Your institution is part of an international group and having issue to adapt a training material that is compliant to the local regulation as well as to mother company’s regulation; 
  • You are facing some reputational risks and you are not able to train your employees on an annual basis to overcome and offset these risks; 
  • The training material developed is outdated and is not well adapted to risks encountered by your institution and its reputational risk;
  • The training material does not address prevention of tax crimes as predicate offenses (aggravated tax fraud and tax swindle) further to the Law dated 23 December 2016 and CSSF circulars 17/650 and 20/744 (for CSSF regulated entities);
  • Management are lacking the understanding of the new legal obligation and require training to provide them with;
  • You are encountering some slowdown and need to speed up to reach the level of knowledge needed to be fully and independently operational and adapt best standard practices within your market. 

How we can help: 

  • Our PwC financial crime team offers a variety of training through several mediums such as online workshops, online training and onsite training/workshops and e-Learning; 

  • The training is presented by subject matter experts with operational and legal experiences that could help address your issues from both a regulatory perspective and best standard practices perspective; 

  • Our aim is to bring our know-how and leverage on our experiences when tailoring our training solution to your needs. Our tailored training solutions cover the following areas: 

AML KYC

Due to the continuous change in AML regulations, our subject matter experts can support you by providing tailored training according to your business needs. Training can covers European directives, transposed laws and circulars (including CSSF circulars 17/650 and 20/744);

This training will also be a chance to share our practical experience through our best standard practices and numerous cases studies. 

Transaction monitoring

Our aim is to explain the regulatory framework to protect your business and guidance on key aspects to follow in order for you to set up an effective transaction monitoring methodology.   

We can assist you in understanding typologies related to your business and your geographical location and help you overcome various risks identified and adapt your transaction monitoring methodology accordingly. Our support will also include transaction monitoring alert case studies and provide you with the necessary information needed to document these alerts. 

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.

Emerge Stronger - Be Efficient

KYC Process optimisation and automatisation

The KYC process is an integral component in an organisation’s overall AML / CTF compliance programme. 

KYC processes are among the most complex workflows of an organisation's overall process landscape. In the current landscape, bearing in mind that ML and TF is developing rapidly and together with technology, organisations are now focusing on digitalisation - new tools and technologies that – if used appropriately – will enable organisations to reduce risks and costs significantly and substantially enhance the user experience.

Your issues:  

  • Process: Manual and time-consuming processes along with a lack of governance lead to significant operational challenges; 

  • Data Quality: Deficiencies in data integrity, veracity and consolidated storage create distortion of Key Performance Indicators and accessibility issues. It also leads to invalid reporting and misinformation to leadership;  

  • Digitisation: digitise your KYC process but are overwhelmed with all of available options in the market; 

  • Design: You require assistance in designing a present and future state of your existing financial crime operating environment. 

How we can help: 

PwC can support you by:

  • Deploying a synergistic team of KYC leaders, KYC specialists and data experts to achieve an optimal future state of your KYC programme; 

  • Performing a thorough analysis of the KYC digitisation process and developing a KYC digitisation strategy underpinned with a business case and KPIs; 

  • Developing a KYC Target Operating Model (TOM) defining the future organisation, describing the end-to-end processes, the data model, the IT architecture, and the ecosystem;

  • Providing you with an implementation road map on  how to implement a KYC TOM that is realistic and allows for quick-wins;

  • Assisting in the system selection process.

Visualisation reporting (Risk navigator tool)

Regulatory changes are constant, and professionals need to adapt to these changes seamlessly and efficiently in order to ensure continued compliance. 

The CSSF has put in place an online survey (questionnaire) in order to collect standardised key information concerning Money Laundering (ML) and Terrorist Financing (TF) risks to which the professionals under its supervision are exposed. This questionnaire contributes to the CSSF ongoing assessment of ML/FT risks present in the industry and forms part of the AML/CFT risk-based supervision approach put in place by the CSSF over recent years.

Professionals are required to provide a series of quantitative and qualitative data (such as number of accounts, services offered, suspicious activities, adequate internal measures, geographical risks etc.). The questionnaire should be completed by the person responsible for the control of the fight against ML and TF (AML/CTF Compliance Officer). Completion of the questionnaire is mandatory for all the professionals subject to AML/CTF requirements. 

Your issues: 

  • Growing complexity of AML/CTF risk: risk-based approach, risk appetite framework and risk assessment; 

  • Data is often not readily available, centralised or pulled from multiple sources; 

  • Consistency checks and analysis of AML/CTF risk management; 

  • Data is out of date and not regularly updated or unstructured; 

  • Ex-post view for reporting only; 

  • Comparative analysis of the figures reported from one year to another is challenging. 

How we can help: 

The Risk Navigator analyses and presents your data from the CSSF questionnaire for proactive risk management purposes. Our navigator is able to simplify the process for you, and provides and all-encompassing industry-wide solution for effectively managing your AML/CTF risks.

  • The tool provides a digital and visual representation to navigate through your AML/CTF risk and to complement existing questionnaire data sets with additional data;

  • It is easy to use and useful for sharing AML/CTF risk management with the relevant management, not only in times of remote working; 

  • It provides Key Performance Indicators and visual reports for comparative analysis and risk appetite monitoring for different years of reporting with embedded consistency and plausibility checks; 

  • The tool is designed to allow the addition of new capabilities and functionality for any other internal/external periodical reporting for AML/CTF risk management purposes; 

  • PwC can also support you with the collection of data required to populate the CSSF AML questionnaire.

Transaction monitoring and screening tools

Your issues: 

  • Your current transaction monitoring and screening system is manual, prone to human error and not efficient for your purposes; 

  • Your system is automated, but is throwing out a unusual amount of false positives and you do not understand why; 

  • You are unsure whether your transaction monitoring and screening system is adequate at detecting suspicious transactions;  

  • You are currently conducting manual sanction screening and are unsure of which lists to screen against and how frequently you need to screen your customers; 

  • You are unsure of how to interpret positive hits or potentially suspicious transactions, and how the escalation process should work;

  • You require guidance as to best practice for transaction monitoring and sanction screening solutions and reporting. 

How we can help: 

1. Assessment of existing monitoring systems 

  • Assess your existing monitoring systems, i.e. transaction monitoring, sanction, and PEP screening tools by reviewing scenarios, parameters, and thresholds considering your business activities and customers;

  • Analyze your existing transaction monitoring program against regulatory requirements and leading industry practices; 

  • Provide advice on sanctions technology strategy to support your existing screening solutions. 

2. Fine-tuning of transaction monitoring scenarios 

  • Identify the AML/CTF risk that you are exposed to and assess if the current scenarios parameterized in your transaction monitoring tool are aligned with the identified risk exposure; 

  • Support you in fine-tune your existing scenarios and to further support you to implement new scenarios based on the existing regulatory framework, market best practices experience and network expertise.  

3. Transaction monitoring optimization 

  • Define pragmatic behavioral transaction-monitoring tools and reports, based on your specific business activity; 

  • Optimize and validate the monitoring thresholds; 

  • Improve the performance of your automated tools.  

4. Support the selection and implementation of an AML / CTF transaction monitoring, sanction / "blacklist" and PEP screening monitoring tool 

  • Assist you in selecting a suitable transaction monitoring / sanctions screening system for your specific needs; 

  • Assist you with alert and threshold settings of the new system; 

  • Perform validation of monitoring logic. 

Design and implementation of mitigation plans

A visit from the regulator can often mean that organisations are unsure of how to proceed to remedy findings raised. By leaving them unattended, they run the risk of having a similar finding in the following year. 

Your issues: 

  • You have received an unfavorable visit from the regulator and are unsure of how to proceed to become fully compliant; 

  • You require assistance in the design and implementation of a remediation plan following a regulatory visit;  

  • You require clarity as to which laws and regulations apply to your organisation and need to be included in your financial crime compliance plan; 

  • Your control environment is undocumented or outdated and no longer fit for purpose. 

How we can help: 

PwC can support you by:

  • Providing assistance with a remediation plan following a visit from the regulator; 

  • Assisting you in presenting a remediation plan to the regulator after coming aware of a regulatory breach; 

  • Assisting you to understand AML/CTF laws and regulations applicable to your  business and what is required in terms of your financial crime compliance plan; and

  • Designing a fit-for-purpose methodology, accurately defining your financial crime control environment, your financial crime risks and how you intend to mitigate those risks. 

ISAE 3000 report for compliance with Laws and regulation / Agreed Upon Procedure (AUP) report for specific testing / Internal Audit Support

Regulatory changes are constant, and businesses need to adapt to these changes seamlessly and efficiently in order to ensure continued compliance. 

AML/CFT procedures and operational controls need to be reviewed and adapted regularly in order to demonstrate compliance with regulatory changes, and in order to ensure that such changes are adequately incorporated in day-to-day operations. Once everything is in place, management and clients may require additional comfort surrounding the strength and robustness of the AML/CTF control environment.

Your Challenges: 

  • Your regulator requires you to ensure that the entire organisation is AML/CTF compliant. You need a way to demonstrate it;

  • You require an independent assessment of your AML/CTF framework (including implementation thereof);

  • You have several due diligence and/or ad hoc requests from third parties and are looking for a way to satisfy them in an efficient manner;

  • You want to be transparent and as such want to communicate on the quality of your AML/CTF internal control environment to stakeholders (including service providers, regulators, clients and investors);

  • You desire to become or remain distinctive compared to other players in the market;

  • You are required to respond to stakeholder needs and prepare a market conform third party assurance report;

  • You lack internal competencies and require skills for performing a Luxembourg specific AML/CTF Internal Audit review;

  • You require specialised Subject Matter Expert support in order to reinforce your third line of defence;

  • You have clients who desire to: 

    • Understand your AML/CTF policies and know if they comply with the laws and regulations;

    • Know whether the clients accounts opened have proper KYC in place;

    • Understand and ensure ongoing due diligence is performed in a compliant manner;

    • Ensure the risk based approach is properly in place and calibrated to the risk identified;

    • Understand suspicious transactions reporting mechanisms and know that they are effective;

    • Understand your sanction screening process and ensure that it is effective.

How we can support you: 

ISAE 3000 Compliance

PwC can support you by issuing an Assurance report on the compliance of your AML/CTF policies and procedures with the current laws and regulations and/or on the design and operating effectiveness of your operational controls. This report can be distributed to any third parties.

Agreed Upon-Procedures («AuP»)

PwC can support you by testing controls and providing you with a report of factual findings and comfort on your AML/CFT control framework. 

This report is for Management purposes only and cannot be distributed.

Internal Audit support

PwC can support your internal audit department partially or completely by co-sourcing or outsourcing a Subject Matter Expert that can be mobilised whenever you need him. 

The advantage is not only his expertise but also his independence and the relevant market and industry insights which he can provide you with.

Preparation for regulatory on-site visits

Money laundering and terrorist financing is a threat to global security, integrity of the financial system and sustainable growth. Laws to combat money laundering and the financing of terrorism are designed to prevent the financial market from being misused for these purposes.  These are very serious problems, particularly when you consider the state of geopolitics on our planet at the moment. The leading global organization trying to help fight Financial Crime is the Financial Action Task Force ( FATF). Due the disruption to business and social activities caused by the COVID-19-related crisis, the FATF and regional FATF-type organisations have postponed the Luxembourg evaluation to October 2021. When the FATF does come Luxembourg, Luxembourg and a selection of its institutions have to demonstrate the existence of, and adherence too, very high standards as well as government regulations. As part of the regulators focus on AML, one can expect a lot of AML-dedicated onsite visits by the CSSF. Organisations need to ensure that they are ready for such visits and that their AML framework is fully compliant with the law. 

Your issues: 

  • Your are expecting a visit from the regulator and are unsure what to expect; 

  • You are having problems to differentiate between the FATF requirements and Luxembourgish requirements; 

  • You feel that you are unprepared to deal with a visit from the regulator. 

How we can help: 

PwC can support you by:

  • Providing training sessions on how to prepare for a FATF visit;

  • Advising you how to understand Luxembourg legal and regulatory language vs FATF language;

  • Reviewing of your key AML/CTF Documents (Policy, Risk Assessments, Risk Appetite Framework) for completeness;

  • Reviewing of the presentation of your AML/CTF framework; and 

  • Providing a Dry Run Workshop including interviews of the compliance officer and the CEO simulating a visit to help identify elements for preparation.

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Due Diligence services

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

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 62133 56 87

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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