ABBL Handbook on AML and CFT

Welcome to the ABBL Handbook of professional obligations in the fight against money laundering and the financing of terrorism.

This interactive handbook forms part of the ABBL's action plan to fight money laundering, and is designed to provide its Members with comprehensive guidance incorporating national and international references. It is the fruit of in-depth consultations across 5 ABBL working groups, involving more than 50 subject matter experts.

Regulations change constantly, and we will endeavour to keep this tool up to date. Please sign up to receive update notifications by email.

Version 15.1.2022

INDEX

Preface

PART 1
PART 2
Annexes
  1. Annex I
    Correlation table – FATF recommendations
  2. Annex II
    Survey of predicate offences to money laundering under Luxembourg law
  3. Annex III
    List of high-risk third countries and persons subject to restrictive financial measures
  4. Annex IV
    Useful links – additional references
  5. Annex V
    Documents – identification/verification of customers
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Purpose and target audience

This handbook is exclusively accessible to ABBL members, providing them with a powerful tool in their AML and CFT efforts. Compliance and other legal professionals are the handbook's target audience, but many other professionals within the ABBL membership may also find the handbook useful. By virtue of its digital nature, the handbook is highly interactive and dynamic, facilitating its consultation by compliance professionals, whilst enabling other professionals to quickly obtain the information they require.

Why did ABBL create the handbook?

AML and CFT are as important as ever and ABBL supports the Luxembourg financial sector's drive to be at the cutting edge of regulatory compliance. By making this comprehensive handbook available to its members, the ABBL is actively contributing to the dissemination of knowledge and the implementation of best practice in Luxembourg.

How did ABBL create the handbook?

Work on the handbook started inside the ABBL in 2018. Across 5 working groups, more than 50 experts met on a regular basis to exchange thoughts on best practice, to a comprehensive guidance document with a hands-on spirit. Subsequently, the ABBL communications team, in consultation with the authors, collaborated with a web design agency to implement the handbook in electronic form.

Author

Catherine Bourin

Catherine Bourin holds a Doctorate in European Law from the University of Rennes and a Masters’ degree in European Law from the University of Exeter (UK). After 3 years as legal researcher at the Laboratoire de Droit Economique (University of Luxembourg), she joined the ABBL in 1999 as legal adviser. In 2011, she became Head of Legal Affairs. Since 2013, she is Member of the Management Board in charge of Legal and Compliance, Social Affairs as well as Human Resources, and supervises the management of ABBL Clusters. She represents the ABBL in a number of Committees at the Luxembourg Central Bank (BCL), the Commission de Surveillance du Secteur Financier (CSSF), the European Banking Federation (EBF), the Luxembourg Federation of Employers (UEL), the Ministry of Finance, the Ministry of Justice as well as the Ministry of Economy. Furthermore, she is President of the Association pour la santé au travail dans les secteurs tertiaire et financier (ASTF). Catherine is a Board member of the Association Luxembourgeoise des Juristes de Droit Bancaire (ALJB), the Association Européenne des Juristes de Droit Bancaire (AEDBF) and LuxFLAG. Catherine Bourin is also lecturer at the University of Luxembourg.

Tel: +352 46 36 60-1 Email: bourin@abbl.lu
Author

Julien Leroy

Julien joined the ABBL in 2017 as Senior Legal Advisor, being notably in charge of anti-money laundering and counter terrorism financing issues together with dossiers involving the processing of the personal data of natural persons. He started his career as a professional cellist before switching to the legal domain as counsel. He has been working over the past fifteen years within the banking/insurance sectors in Luxembourg and overseas. Julien notably worked together with Yves Mersch in the European Coordination Office of the Luxembourg central Bank (Eurosystem) to coordinate the legal briefings of the Governor to be debated at the Governing Council of the European Central Bank, before joining Foyer International in advising/ counselling the company on various European and cross border legal and compliance issues over several EU markets with regard to unit-linked life insurance vehicles. At European level, Julien is a member of the Anti-Money Laundering and Financial Crime Committee as well as the Data Protection and Privacy Working Group of the European Banking Federation (EBF). In Luxembourg, Julien is a member of the national committee for the prevention of money laundering and the financing of terrorism. Julien holds a Bachelor of Commercial Law and two Masters of Laws (LL.M.) in business law and in European banking and financial law from the universities of Luxembourg and Paris II Panthéon-Assas.

Tel: +352 46 36 60-1 Email: leroy@abbl.lu