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Compliance Officers Playbook

CSSF AML/CFT Asset Due Diligence FAQ

15 Dec 2024

Description

This FAQ document, published by the Luxembourg CSSF (Commission de Surveillance du Secteur Financier) on 13 December 2024, clarifies AML/CFT (Anti-Money Laundering/Combating the Financing of Terrorism) asset due diligence obligations under CSSF Regulation 12-02. It addresses the frequency of risk assessments, particularly for securities admitted to versus not admitted to regulated markets. The document stresses that professionals are responsible for conducting their own ML/TF (Money Laundering/Terrorist Financing) risk assessments, implementing appropriate mitigation measures, and documenting their due diligence. It emphasises a risk-based approach, requiring more thorough due diligence for higher-risk assets. The FAQ explicitly excludes international financial restrictive measures from its scope.

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