AML/FT In The Private Banking Sector

On 20 December 2018, the CSSF issued Circular 18/702 ("Circular") relating to new developments regarding the fight against money laundering and terrorist financing ("AML/FT") in the private banking sector.

The Circular addresses banks and professionals of the financial sector that provide services in private banking (i.e. wealth management). Given that private banking activities show a high risk of money laundering and terrorist financing, the CSSF has decided to give targeted guidance in order to prevent and mitigate those risks. This Circular establishes a list of categories of clients who are most at risk; a list of risks that cannot be mitigated and therefore need to be excluded from the practice; and a list of mitigating measures that should be taken into account in the presence of...