Regulatory Alerts2018-12-20
Added · Updated
Circular CSSF 18/702 — Developments regarding the fight against money laundering and terrorist financing in the private banking sector
The CSSF requires private banking professionals in Luxembourg to exclude unsustainable business models reliant on high-risk customers and to reject clients for whom the origin of funds or source of wealth cannot be verified. Institutions must implement specific mitigating measures, including rigorous documentation of ultimate beneficial owners, critical appraisal of transaction purposes, and the involvement of the group head in customer acceptance and risk control. The CSSF will sanction serious deficiencies with significantly higher penalties under Article 8-4 of the Law of 12 November 2004 and will intervene against professionals whose business models retain residual risks deemed too high.
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