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 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.

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.

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

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

Michael leads PwC’s Forensic Services practice and AML taskforce, overseeing investigations, remediation projects, and high-profile AML audits for banks and investment funds. He is the key contact for AML distribution due diligence in asset management and works closely with PwC’s global forensic network on international projects. As certified fraud examiner, Michael is recognized as an AML and forensic expert and actively contributes to industry working groups on fraud at the Institute of Internal Auditors (IIA) and the Institut Luxembourgeois des Administrateurs (ILA). He regularly conducts workshops and training on AML and fraud in Luxembourg and abroad.