Compliance with AML/CTF requirements

Comply with the AML/CTF requirements

AML/CTF responsibilities

Assignment of the roles of the compliance officer & the person responsible for compliance in compliance with CSSF Regulation n°12-02 as amended.

Compliance Plan

Fast formalisation of a comprehensive AML/CTF Compliance Plan thanks to a pre-configured and continuously updated knowledge base.

AML/CTF controls

Save time and efficiency in carrying out your AML/CTF inspections thanks to customisable checklists.

AML/CTF reports

Many templates available. Downloading of the compliance officer report and controls follow-up reports in a few clicks.

AML/CTF Responsibilities

CSSF Regulation n°12-02 as amended defines the tasks of the compliance officer & the person responsible for compliance.

The formalisation of an AML/CTF compliance plan enables the organisation of the duties of the compliance officer & the person responsible for compliance and ensures that all the requirements of CSSF Regulation 12-02 have been taken into account.

  • He implements the AML/CTF policy;
  • He controls the compliance with professional obligations applicable to branches and subsidiaries;
  • He implements the ongoing training and awareness-raising programme for staff;
  • He is the main contact person for the authorities in charge of AML/CTF;
  • He implements regular controls at a determined frequency according to the AML/CTF risks identified;
  • He reports regularly in writing and if necessary, on an ad hoc basis to the authorized management and, if necessary, to the board of directors;
  • He prepares a summary report on its activities and operations at least once a year. This report is submitted by the CO to the person responsible for compliance for approval by the Board of Directors. It is submitted to the authorised management for information;
  • The supervisory system must be subject to initial validation by at least the person responsible for compliance and regular monitoring by the compliance officer in order to adapt it, if necessary, to activities, customers and AML/CTF standards and measures.
  • The person responsible for compliance must submit annually to the CSSF the summary report of the compliance officer for the past year within five months following the end of the professional's financial year;
  • The supervisory system must be subject to initial validation by at least the person responsible for compliance and regular monitoring by the compliance officer in order to adapt it, if necessary, to activities, customers and AML/CTF standards and measures.

AML/CTF Compliance Plan

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AML/CTF Controls

Save time and ensure the completeness of your AML/CFT controls.

Our checklists are customisable, adapted to different types of companies and continuously updated according to the evolution of the legal & regulatory framework.

Assign controls to different people. Formalise the implementation of recommendations and their follow-up.

Document the controls by attaching your supporting documents.

Identify the weaknesses in your AML/CFT policies and procedures so that they can be addressed quickly.

This questionnaire is based on 155 questions divided into 18 topics.

Questionnaire focused on the following areas:

  • Formalization & approval of the AML/CFT procedure
  • Legal & regulatory references
  • Obligation of adequate internal organisation
  • Designation & communication of AML/CTF responsibles
  • Use of the GoAML platform
  • Staff training & awareness
  • Definition of key AML/CFT concepts
  • Customer identification measures
  • Individual risk analysis
  • Global risk analysis
  • Definition of simplified due diligence
  • Definition of enhanced due diligence
  • Definition of AML/CFT risk appetite
  • Identity verification measures
  • Customer acceptance policy
  • Ongoing vigilance measures
  • Obligation to cooperate with the authorities
  • Formalization, acknowledgement and approval of the AML/CFT report of the manager

 

Article 2-2 of the Coordinated Law of 12 November 2004 : « The professionals shall take appropriate steps to identify, assess and understand the risks of money laundering and terrorist financing that they face, taking into account risk factors including those relating to their customers, countries or geographic areas, products, services, transactions or delivery channels.»

Based on 74 questions, this questionnaire will allow you to define your BC/FT risk appetite.

Questionnaire focused on the following areas:

  • AML/CTF responsibilities
  • AML/CTF procedure
  • Customer review (KYC)
  • Transaction review (KYT)
  • Control solution
  • Definition of occasional customers
  • Suspicious transaction reports
  • Staff training & awareness
  • Customer risk factors
  • Product/service risk factors
  • Geographical risk factors
  • Definition of risk appetite
  • Definition of inherent risk
  • Definition of mitigation measures
  • Definition of residual risk

Identify the weaknesses in your KYC files so that you can quickly address them.

This questionnaire is based on 35 questions divided into 8 topics.

Questionnaire focused on the following areas:

  • KYC files review
  • KYT files review
  • Review of identification forms
  • Review of individual risk analyses
  • Review of customer acceptance forms
  • Review of clients’ identification and identity verification documents
  • Review of ultimate beneficial owners’ identification and verification documents
  • Review of proxies' identification and verification documents

Ensure your compliance with CSSF Circular 18/698 thanks to a 196 items questionnaire divided into 22 topics.

Quickly identify your weaknesses in order to remedy them efficiently thanks to precise action plans.

Questionnaire focused on the following areas:

  • General Assembly
  • Board of Directors
  • Management Committee
  • Policies and procedures
  • Internal Audit
  • External audit
  • Risk management
  • Compliance
  • Portfolio
  • Delegation
  • Evaluation
  • Information
  • Programme
  • Human Resources
  • IT
  • Accounting
  • Head Office
  • Marketing
  • Proportionality
  • Finance
  • Insurance
  • AML/CTF

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Address

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email

info@vigil.lu

Phone

+352 26 30 89 35

Mobile

+352 661 777 987

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