This document summarises the key takeaways from the joint ABBL–CSSF workshop on “Overcoming KYC Challenges”, held on 4 July 2025 at the Chamber of Commerce in Luxembourg. It provides practical guidance and regulatory clarifications on AML/CFT expectations, with a strong emphasis on the risk-based approach as the cornerstone of effective compliance. The document covers key topics such as document updates, trigger events for account reviews, UBO identification, due diligence for regulated entities, PEP treatment, complex structures, tax residence verification, remote onboarding, transaction screening and SAR reporting. It highlights the CSSF’s position that compliance should focus on the effectiveness of risk management frameworks rather than purely formal documentation, and that institutions must demonstrate a proactive, proportionate and well-documented approach to financial crime prevention. The conclusions also underline that minor documentary deficiencies alone should not trigger sanctions, provided the overall AML/CFT framework is robust and effective.
