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Real Estate Agents in Luxembourg - Start drafting your AML procedures manual.

Now that you have done your proper business risk assessment, you should apply a risk-based approach, and set up internal procedures and policies which are proportionate to your business, clients and operations, without, of course, neglecting the risks involved


These internal policies are documented in a procedures manual, or handbook, and then easy to follow by all of your agents and employees.


What should be in such a manual?


A description of your professional obligations. Written in a way that they are complete, easily understandable and integrating practical aspects.


There should be room for describing the controls you will put in place to ensure compliance with these procedures, and how you are regularly updating your risk analysis. Also, say a word how your documents and records are kept. How you are processing personal data (GDPR compliant).


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 you must 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 done, you may book an appointment with one of our experts.


Book an online appointment HERE.






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