Not a day goes by when financial and non-financial media do not make reference to the intention of politicians, economists and law makers to strengthen the current measures against money laundering (AML) and terrorism financing. More and more sanctions are imposed for the non-respect of AML and terrorism financing duties by financial supervisory authorities and by judges.
An efficient participation in the fight against money laundering and terrorism financing implies a good knowledge of the existing laws and regulations but also of the permanent professional duties. Faced with increasing regulatory duties, the management and the employees are often overwhelmed and cannot meet said duties if they have not been clearly defined.
As part of this course, PwC's Academy offers to highlight your company's requirements regarding this topic and to address in a comprehensive and practical way the questions participants are confronted with in the light of mandatory professional duties and the "progressive" evolution of AML regulations.
Thanks to our strong expertise in the financial sector and our professional experience, we can help participants improve their AML knowledge according to the best practices.
Duration:
- 2h (remote)
- 3h (classroom)
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)
Objectives
By the end of this training, participants will be able to:
- identify the impacts of the regulatory requirements on their organisation;
- set up and apply a risk based approach;
- extend the procedures applicable to a Luxembourg entity to an international group;
- explain the relevant regulations and the possible consequences of negligence or breach to other employees;
- draw up an internal AML framework in line with the requirements;
- draw up the internal AML assessment.
Content
Our training is focused on:
- answering legal requirements;
- taking into account the latest legal and regulatory international, European and Luxembourgish changes and the latest CSSF and FIU circulars, regulation and annual reports;
- giving concrete examples extracted from the press and from the professional experience of speakers;
- a pragmatic approach to elaborate duties depending on participant activities and team size.
Theoretical part
Development of essential definitions
Overview of the recent regulatory environment at Luxembourgish, European and international levels
Scope of primary offences
Practical part
Presentation of professional obligations and illustration with practical examples
Customer due diligence (identification and verification of the identity, name checking, origin of funds etc. for individuals and legal persons)
Criteria related to the “risk based approach” (nationality, country of residence, professional activity, PEP etc.)
Transaction monitoring (incoming, outgoing, name and country screening, amount, frequency, IT tools etc.)
How to cooperate with the FIU (who, when, what, “no tipping off” principle)
Adequate internal organisation (framework, IT tools, record keeping) and controls (hierarchical, internal audit, compliance function etc.)
Overall, this training is interactive and full of useful practical points, multiple-choice questionnaires and case studies.
Target audience
- Members of executive committees and boards of banks, professionals of the financial sector, insurance companies, or management companies of a Luxembourg UCI
- Internal auditors, compliance officers or risk managers
- Distributors or transfer agents of a Luxembourg UCI
- Domiciliary agents
- Persons in charge of front office team members of a PFS
Fighting against money laundering and terrorism financing is the responsibility of each employee. Nevertheless, the management has to set an example.
Our lead experts
This training is coordinated by Cécile Moser and Michael Weis, Partners at PwC Luxembourg and will be given by directors and managers who benefit from a strong professional experience in this area.
Cécile, AML Services Partner, is specialised in the financial sector of Luxembourg, with a particular focus on AML and CTF regulations and internal control environments.
She manages and performs regulatory mandated AML and CTF reviews, identifies AML and CTF control issues or deficiencies for private banks, custodians, transfer agents, investment funds and management companies.
Cécile also provides advice on AML and CTF methodology and helps to develop AML/CTF procedures in line with local laws and regulations.
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).
