Anti-money Laundering Essentials

To know the new regulations and all concerned laws and circulars.
To identify all the risk areas by a risk based approach.
To avoid any responsibility for the bank.

History of Compliance

• Origins of Compliance, organisation of a good governance, different levels of controls.
• International recommendations, judicial and national authorities.

Understanding of Compliance

• Definition of the money Laundering and definition of the terrorism financing.
• Description of the three steps of the money Laundering…
• Entities concerned by the money Laundering and the terrorism financing.
• Operations considered as infraction to the Penal Code.

Master the legal frame of the fight against money Laundering

• Recommendations of the FATF.
• The 4° directive anti-money Laundering.
• Luxembourg legal framework.
• Penalties: responsibilities if failures in controls put in place by the organisation, statement of suspicion and civil and penal responsibilities.
• Development of the best practice: analyses FATF and COE – Moneyval.

Detailed analysis of the Luxembourg's FIU

• CRF (Cellule de Renseignement Financier) and AED (Administration des Enregistrements et Domaines).
• Last statistics.
• Recommendations of the CRF.

Exercise: analysis of a model of a statement of suspicion.

Build and perpetuate a plan of fight against money Laundering

• Elaborate a manual of procedures and a Compliance plan.
• Relations with the other control departments: relations with the internal and the external auditor, improvement of the cooperation between the different levels of control, in house controls by the CSSF, contacts and reports with the CRF.
• Elaboration of a training plan.
• Tools and techniques of investigation: AML tool, scheduled controls (KPI, KRI…), analysis of the CSSF circulars (anti-money Laundering), permanent analysis of the PEP’s, of the concerned countries placed by the FATF in grey and dark lists, schedule of reportings for the
• Management and for the regulators.

Exercise: build a risk based approach: countries risks/Clients risks (KYC)/Products risks.

Attestation de participation