Due diligence obligations are clearly outlined by Luxembourg law and guidelines issued by control authorities.
This obligation applies when :
the Agent establishes a business relationship with the client;
the Agent executes, on an occasional basis, a transaction of an amount of EUR 15,000 or more, whether that transaction is carried out in a single operation or in several operations which appear to be linked;
there is a suspicion of money laundering or terrorist financing, regardless of any derogation, exemption or threshold;
there are doubts about the veracity or adequacy of previously obtained customer identification data.
They have 4 different aspects:
Your manual of procedures shall detail these obligations, starting with client identification.
We have set up a template procedures manual, which you are able to customize to your proper needs in 40 minutes time. It comes with instructions, and a 10 step-plan, indicating the places where your input is still needed to customize the manual.
Download this template HERE. We have English, French and German language versions available.
If you would like assistance to validate your manual of procedures you have issued, you may book an appointment with one of our experts.
Book an online appointment HERE.