Your challenges
You must mitigate any risk of non-compliance with your AML tax obligations, but you are facing following operational challenges:
- Integrate AML tax risk into your current AML process (incl. risk appetite, checklists, risk scoring)
- Equip first and second line of defence to assess the appropriate tax fraud indicators of CSSF-FIU Circular 17/650
- Differentiate complex structures of your clients / investors with a genuine business purpose from non-transparent structures
- Determine which documentation could reduce the risk of tax fraud
- Monitor tax compliance of your structures at investment level (CSSF Circular 20/744)
- Understand the interactions with the other regulations (i.e. FATCA/CRS and DAC 6)
- Integrate those elements into a robust compliance program
Our AML tax services
We can help you to manage your operational AML tax challenges:
We can assist you with the drafting of AML tax procedures, on-boarding checklists and a tax matrix, taking into consideration the specificities of your activities and type of clients / investors you have in your portfolio.
- We can review a sample of complex clients / investors and assess the tax transparency risk of those accounts (high/medium/low).
- Upon request, we can review your current procedures, on-boarding process and tax matrix to assess whether there are any GAPs from a tax transparency point of view.
- We will provide you with a remediation plan to reduce the risk level.
We can provide generic or dedicated AML tax trainings to relevant employees to ensure that they are comfortable with the AML tax regulations, understand their practical impact and can identify any potential risks.
Upon request, we can review complex client / investor cases at the on-boarding stage or during periodic reviews.
Please note that all those tax services could be integrated in the global AML service offering of PwC.
Contact us
Pierre Kirsch
Tax Partner and Authorised Manager of the PSF, PwC Regulated Solutions S.à r.l.
Tel: +352 49 48 48 4031
Frauke Anna Maria Ortmann
Tax Director, PwC Regulated Solutions S.à r.l.
Tel: +352 62133 37 62