Regulatory Alerts2023-10-16
Added · Updated
CSSF Circular 23/842: Adoption of Revised EBA Guidelines on Money Laundering and Terrorist Financing Risk Factors
The CSSF integrates the EBA amending guidelines (EBA/GL/2023/03) into its administrative practice and regulatory approach, requiring credit and financial institutions to apply specific criteria when assessing money laundering and terrorist financing risks associated with not-for-profit organizations. These institutions must obtain a detailed understanding of an NPO's governance, funding, activities, and beneficiaries, while considering defined risk factors such as legal status, reputation, funding transparency, and operations in high-risk jurisdictions. The guidelines, which replace Guideline 2.7(d) of the original risk factors framework, became applicable on 3 November 2023 and apply to entities defined under the Law of 12 November 2004 on the fight against money laundering and terrorist financing.
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