On 20 December 2019, the CSSF released its money laundering/ terrorist financing risk assessment for the private banking sector. The report was drafted in close cooperation with members of the Private Banking Group of the ABBL (PBGL), which gathers executives and senior representatives of institutions active in private banking.
During dedicated meetings held with the CSSF, the PBGL exchanged their insights as to the inherent money laundering risks posed by private banking activities, and on the mitigating factors employed by professionals to reduce the risks involved.
It is to be noted that the national risk assessment deems the residual risk of the private banking subsector as “Medium-High”, after having taken into consideration all of the mitigating factors mentioned.
The newly created Private Banking Expert Working Group will continue to focus on these topics during 2020, in close collaboration with the CSSF and the Financial Intelligence Unit.
By Julien Leroy, Senior Legal Adviser, ABBL
