Going beyond AML: fraud, corruption and whistleblowing

One could say that by default, Luxembourg has a very strong focus on AML. Topics that are not directly linked to the fight against money laundering and terrorism financing are not heavily regulated and therefore often overlooked.

But where does the money that is being laundered actually come from? Wouldn't it make sense to cut off the sources of illicit money instead of focusing so much on how it might be moved through the financial system?

Both fraud and its sub-category, corruption, are predicate offences for money laundering, meaning they can be sources of illicit money. Perpetrators can be both externals, such as cybercriminals but also business partners, and internals or both can work in collusion. An anti-fraud and anti-corruption programme including thorough checks of your suppliers and vendors can be an effective instrument to reduce the risks linked to these offences and the following money laundering schemes. Other countries already demand the implementation of such programmes and a new 'ABC' (Anti-Bribery and Corruption) package by the EU will soon introduce further standards just like the AML directives did.

The adoption of the law on whistleblower protection in May 2023 is a further addition to these efforts since internal alert systems are generally considered as one of if not the most efficient fraud detection mechanisms.

PwC's Academy offers this course in order to go beyond AML and to equip participants to better protect their organisation from financial losses, fines and reputational damage. Together with members of the anti-financial crime team participants will discuss current and upcoming legal requirements, practical tips for implementation and best practices.

Duration: 2h

Language: Available in English, French, and German. The supporting material is only available in English

Number of participants: up to 15

Available under intra-company course (i.e. dedicated session on demand)

Dedicated sessions are also available in a 2-hour format for specialists and in a 1-hour format for board members and C-suite executives.

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Objectives

At the end of the course, participants will be able to:

  • explain how different forms of financial crime are connected and why they should be considered holistically;
  • understand the different national, EU and international requirements (both current and upcoming);
  • discuss the elements of standard anti-fraud management system;
  • identify the steps to implement an anti-fraud management system in their organisation.

Content

This module covers the following:

  • Overview of different forms of fraud and corruption
  • International and national laws, regulations and penalties
  • Components of an anti-fraud programme
  • Elements of a whistleblowing system
  • Governance structures and internal controls
  • Third party due diligence
  • Risk assessments
  • Case studies and discussion

Target audience

  • Representatives of all sectors (financial, private and public)
  • Members of the board or management
  • Internal auditors, compliance officers or risk managers
  • Legal and HR department

Our lead experts

This training is coordinated by Michael Weis, Partner at PwC Luxembourg. The training will be given by directors and managers who benefit from a strong professional experience in this area.

Michael is lead-partner for the Forensic Services practice and of the AML taskforce.

Michael is regularly acting as engagement leader for a large variety of forensic investigations including AML investigations, remediation and prevention projects in asset management and banking.

In this context he is also responsible for high-profile AML audit missions as part of the legal audit requirements for Luxembourg banks and investment funds.

As key contact of the AML distribution due diligence service for the asset management industry, Michael is regularly involved in country risk assessments and the review of laws and regulations of country AML frameworks.

Michael is coordinating projects with the global PwC forensic network and regularly involved in large scale international projects of PwC for investigations and FTS related work. Michael is part of the Global Forensic Network WG on L&D. as CFE (Certified Fraud Examiner).

Michael is recognised in Luxembourg and abroad as a subject matter expert on AML and forensic matters as a key member of the local industry working groups on fraud at the Institute of Internal Auditors (IIA) and the Institut Luxembourgeois des Administrateurs (ILA) for directors. Michael regularly facilitates workshops and trainings on AML and fraud, both in Luxembourg and internationally, in the asset management and banking sector. Michael is also an active member of the Local Compliance Officer Association (ALCO).

Other modules

You may be also be interested in the following related modules. These are deliverable on demand:

 

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