Formation - Anti-Money Laundering Practice

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.