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This training aims at explaining the Anti-Money Laundering (AML) rules and professional obligations currently applicable to Luxembourg financial institutions and will focus on their practical implications. The training will in particular highlight the main changes and practical impacts from the 4th AML Directive and the law implementing the 4th AML Directive into Luxembourg law and those brought by the new regulation 2015/847 on information accompanying transfers of funds. The purpose of the training is also to be very practical and thus it will also focus on existing case law available, administrative practice from the CSSF and on a number of practical examples.
Definitions and illustrations of key concepts
“Know Your Customer” (KYC) obligations: practical focus on the definition of beneficial owner, customer due diligence measures (enhanced and simplified), recourse to a third party to carry out KYC duties
Internal organisational requirements for financial institutions
Practical approaches to the obligations to cooperate with the relevant authorities (i.e. filing a suspicious transaction report, practical case studies, no tipping-off obligations, dealing with freezing orders, examples of recent case law, etc.)
Evolution of good and poor AML practices on the basis of the latest activity reports of the Cellule de Renseignement Financier, the CSSF’s annual report, administrative practice from the CSSF and case law precedents
Special focus throughout the training on the main changes from the 4th AML Directive and the law implementing the 4th AML Directive into Luxembourg law, as well as their practical impacts on Luxembourg legislative framework and financial institutions including i.e.:
- new register of beneficial owners
- the inclusion of “tax crimes”
- mechanism of the risk based approach and the new risk factors applicable simplified and enhanced due diligence
- more generally, description of the new requirements of the 4th AML Directive and the law implementing the 4th AML Directive into Luxembourg law, including the relevant guidelines in this field
Changes to be expected from the new regulation 2015/847 on information accompanying transfers of funds.
Potential other developments of the existing Luxembourg legislative framework, the European or international AML standards (e.g. FATF-GAFI recommendations) and changes in the regulatory and prudential rules applicable to Luxembourg financial institutions (e.g. amendment of the relevant circular letters), including the main changes to be expected from the "5th AML Directive".
Glenn Meyer (Partner, Banking and Financial Services, Arendt & Medernach).
Professionals in charge of front office, administration, legal and compliance functions in banks or other professionals of the financial sector.
For any information, please contact us by e-mail firstname.lastname@example.org