Formation - Anti-Money Laundering Practice
Reinforce your organisation.
To identify all the risk areas by a risk based approach.
To avoid any responsibility for the bank.
Persons in charge of the anti-money Laundering activities.
Every person in charge of the procedures concerning the anti-money Laundering activities.
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.