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Latest news:

- [NEW] Learn more about AML/CFT compliance - Tax services here_
- [NEW] 17 January 2023 - AML/CTF precautions important even for small players - Glenn Meyer and Sandrine Périot - Delano
- 1 July 2022 - Article - Taking risk-sensitive measures to fight financial crime, Sandrine Périot - Paperjam
- 16 June 2022 - Article/Podcast - The challenges of Economic and Financial crimes, Stéphanie Lhomme, Sandrine Périot and Jean-Luc Putz - Paperjam
- 28 April 2022 - Video - The latest on asset-side AML due diligence (in the frame of the 'Let's talk real estate' series)

Money laundering and terrorism financing are threats that require constant vigilance. The pressure and regulatory scrutiny at the national and international levels is intensifying with the imposition upon companies of ever more complex global AML/CFT rules, including due to international financial sanctions. Accordingly, there has been a significant rise in supervisory activities and regulatory expectations, creating a zero-tolerance environment in which any shortcoming could result in serious reputational damage and heavy fines for companies or individuals.

Every day, Arendt works to ensure that its clients remain compliant with their AML/CFT requirements in this constantly changing environment, so as not to become unknowing contributors to illicit activity.
Arendt is uniquely positioned to understand and help you face the many challenges entailed by your AML/CFT obligations. We would be pleased to assist you in the prevention and detection of ML/TF concerns and risks while also equipping your company to properly respond to any deficiencies, and to implement a suitable AML/CFT compliance programme where necessary.

The full value chain under one roof

You are

We assist clients in all sectors, from investment funds and asset managers to banks, financial institutions, professional of the financial sector and insurance companies, and even non-financial actors with AML/CFT concerns. Arendt helps you operate effectively and within the bounds of your legal and regulatory obligations, advising on how to meet them for any sector and how to implement standards that ensure business integrity, compliance, transparency and security.

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Your contacts

Contact our experts to identify the best options for you from our range of services: AMLCFT@arendt.com

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Prevention Stay ahead of your AML/CFT obligations

Framework and governance review

• Design and review of policies and procedures, including gap assessment for full compliance with AML/CFT rules taking into account the specifics of your industry
• Review and assessment of your control and governance framework and assistance with any further enhancement, update or measures

Risk assessment and risk-based approach

• Design and review of your risk assessment methodology, including the asset risk assessment approach
• Design and review of your country risk assessment methodology, including the performance of country risk assessments
• Assistance in the completion of your annual risk assessment (inherent and residual risks) and subsequent reporting
• Review, drafting and implementation of a risk-based approach specific to your organisation
• Design and review of your AML risk appetite and KPIs/KRIs

Training and awareness programme

Online and on-site training performed by subject matter experts, tailored to your needs and specifics

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Ongoing life cycle Stay efficient when complying with your AML/CFT obligations

Health check, mock inspection and regulatory on-site inspection (OSI) preparation

• General suitability review of your AML/CFT internal control framework (key policies and procedures, processes and governance documents) to ensure consideration of regulatory requirements
• Preparing your company for regulator visits: interview preparation, review of presentations for introductory meetings with the CEO and CCO, review of key AML/CFT policies and documents, sample testing, etc.
• Assistance during regulatory on-site inspections

AML compliance assistance

• Provision of AML/CFT, tax and legal experts to address all AML compliance needs: completion of annual AML/CFT questionnaires and market entry forms, review and preparation of RC reports, drafting of policies and procedures, performance of KYC/CDD and ODD (clients, investors, distributors, delegates, assets), assistance treating transaction/screening alert backlog, assistance with goAML registration and STR/SAR preparation, etc.
• Hotline to AML/CFT, tax and legal experts who answer your AML/CFT queries on demand
• AML/CFT-oriented legal assistance in drafting and reviewing prospectuses and issuing documents, subscription and application documents and service provider agreements, as part of investment fund development or banking and insurance licensing

RBE/RFT services

Support in the identification of Ultimate Beneficial Owners of Luxembourg entities or fiducies and trusts and related analysis, and in filing UBO-related information with the RBE or RFT to meet registration obligations under the RBE and RFT laws

Screening and transaction monitoring assessment

• Review and assessment of potential suspicious transactions and reporting to the FIU, including legal assistance regarding SAR/STR fillings and sanctions
• Assessment of your current name screening/transaction monitoring tool setup (review of parameters, scenarios, thresholds, data quality, etc.) and assistance implementing any corrective measures needed to improve efficacy
• Assessment of the effectiveness of the transaction monitoring process (treatment of hits, documentation, detection of AML/CFT typologies, overall monitoring during the relationship) and assistance implementing any corrective measures
• Design and review of screening and transaction monitoring procedures, including gap assessment to ensure compliance with current AML/CFT rules, taking into account the specifics of your industry 

MLRO/AML officer/RC mandates

• Provision of RC mandates
• Provision of advice and support to your MLRO/AML Officer/RC
• Drafting and review of documents and agreements relating to the appointment of the RR/RC

Counterparty due diligence (customer, distributor/intermediary, delegates, asset)

• Assistance conducting initial and ongoing due diligence on counterparties
• Review of your existing approach, framework and contractual agreements
• As part of M&A during business pre-deal (buyer or seller), review of target’s AML/CFT framework and issuance of a specific due diligence report

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Response Stay responsive to resolve shortcomings in your AML/CFT compliance programme

AML/CFT response following on-site inspection by regulators

Legal assistance to properly address and respond to sanction letters, fact validating meetings, etc.

AML/CFT mitigation programme

• Assistance defining and implementing a mitigation action plan to address shortcomings identified following an on-site visit, including discussion with the regulators
• Following framework review, assistance implementing corrective measures to address deficiencies identified in your control environment
• Assistance in the remediation of shortcomings identified following a health check or a mock inspection

AML/CFT remediation exercise

Assistance designing and implementing a remediation exercise/plan (including KYC/KYT and tax aspects) combining subject matter expertise and technological capabilities, as part of backlogs, due to trigger event circumstances, following migration of client portfolio, etc.

AML/CFT investigation

Assistance investigating any ML/TF incidents, allegations or suspicions to enable you to quantify, take appropriate action and prepare your case if required

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Definitions

AML: anti-money laundering
CDD: customer due diligence
CFT: combating the financing of terrorism
FIU: Luxembourg Financial Intelligence Unit
GP: general partner
IFM: investment fund manager
KRI: key risk indicator
KYC: know your customer
MLRO: money laundering reporting officer; RC: responsable de contrôle
OSI: on-site inspection
RBO: Register of Beneficial Owners; RBE: registre des bénéficiaires effectifs
SAR: suspicious activity report
STR: suspicious transaction report
TFS: targeted financial sanctions
UBO: ultimate beneficial owner

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Related content

Newsflashes

26/07/21 - The new EU AML-CFT package

21/01/20 -  Anti-money laundering and counter terrorist financing – mandatory survey due in March 2021

11/09/20 - New AML / CFT CSSF Regulation and Grand-Ducal Regulation

11/09/20 - New CAA AML / CFT regulation

31/03/20 - Law of 25 March 2020 establishing a central data retrieval system for bank, payment accounts and safe-deposit boxes

30/03/20 - Implementation of the 5th AML Directive into Luxembourg law: the last piece of the puzzle – Key aspects and changes of the law of 25 March 2020

22/11/18 - The Luxembourg registers of beneficial owners (“BOs”) expected soon, so get ready!

22/06/18 - 5th AML Directive - Key aspects

06/06/18 - The fifth anti-money laundering and terrorist financing directive (AML 5) - Key aspects and changes

Press/media/publications

[NEW] 17/01/23 - AML/CTF precautions important even for small players - Glenn Meyer and Sandrine Périot - Delano

01/07/22 - Article - Taking risk-sensitive measures to fight financial crime, Sandrine Périot - Paperjam

16/06/22 - Article/Podcast - The challenges of Economic and Financial crimes, Stéphanie Lhomme, Sandrine Périot and Jean-Luc Putz - Paperjam

12/11/20 - French only - Obligations AML, qui n’est pas concerné?

30/01/20 - French only - Lutte contre le blanchiment d’argent et le financement du terrorisme – Quand le risque pénal du banquier cède le pas face au risque administratif - (01/2020) Glenn Meyer (AML)

Webinar Recordings - Past events

26/10/22 - Webinar - White-collar crime: how to handle a crisis and scandal-proof your organisation

28/04/22 - The latest on asset-side AML due diligence

24/02/21 - All you need to know about the recent evolutions to the AML-CTF framework in the insurance sector

Financial crime [Hot topic]_

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