All real estate agents operating in Luxembourg are required to fully cooperate in the fight against money laundering and the financing of terrorism. To this end, they must put in place adequate and appropriate procedures.
You do not yet have an internal AML procedure? This plan will enable you to be compliant and confident for any control exercised by the competent authorities. Three steps are sufficient:
Step 1 - Assess the risk of your activity
Why should you do this?
This is an absolutely necessary prerequisite for the development of your procedure manual.
The matrix is divided into two parts: 1. assessment of the risks related to the company; 2. assessment of the risks related to business relationships and clients.
Actions to take:
1) Download a fully ready-to-use assessment matrix template HERE.
Price:
EUR 0 - if you download directly the procedure manual template (see step 2) which also contains the evaluation matrix
EUR 90 - if you only want to download the evaluation matrix
2) Fill in the form. Sign it. Save it.
Time required: 1 hour
Prerequisite: Statistics on the number of clients and transactions over the last 3 years.
Step 2 - Validate your procedures manual
Why should you do this?
This is a document required by the Grand Ducal Regulation of 1 February 2010 (Article 7).
The manual contains the procedures, policies and controls that you must put in place to cover customer due diligence, record keeping, detection of unusual or suspicious transactions and the obligation to report suspicious transactions.
Actions to take:
1) Download a fully ready-to-use procedures manual template, HERE.
Price: EUR 420
2) Adapt the template to your needs. It comes with instructions and a 10-step plan, indicating where your input is still needed to customize the manual. Save the manual once you have customized it.
Time required? 40 minutes
Prerequisite: Logo. Picture of your agency.
Step 3 - Appoint your AML Compliance Officer
Why should you do this?
The Compliance Officer is responsible for AML/CFT controls. He or she is the main contact for the Public Prosecutor's Office and the AED.
Actions to take:
1) Appoint your Compliance Officer. Take care to indicate his or her name in your procedures manual.
Price: EUR 0
Don't have an internal person to take on the role of Compliance Officer? Consider an external person. AML4YOU acts as a external & freelance AML Compliance Officer. We have set up a plan of 8 hours per month. Cancelable at any time. 14 day free trial period.
Price: EUR 960 / month
2) Adjust his or her workload, if necessary, so that his or her AML/CFT mission is not compromised. Provide appropriate training.
Time required? 10 minutes
Prerequisite: None
Step 4 (recommended) - Annual subscription
For any procedure manual downloaded via AML4YOU, you can take out an annual subscription. This ensures that your procedures manual is kept up-to-date with published updates when legislation changes.
Price: EUR 50 / year
Step 5 (optional) - Personal assistance
If you would like AML4YOU to assist you in setting up or validating your procedures manual or your internal risk analysis, or in making suspicious declarations, you can make an appointment with one of our experts.
Book your appointment HERE.
Price: EUR 180 / hour