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Real Estate Agents in Luxembourg - You have a duty to assess your business risk

Updated: Jan 18, 2021

The first step towards effective AML (anti money laundering) procedures and policies is to draft a proper business risk assessment. This is something unique to your agency's business and cannot be copy-pasted from any source.


Take an hour of focussed time. Sit down and first review the following:

  1. type of clients, their number and origin, and if they are natural or legal persons

  2. the field where your customers are active in

  3. type of properties you are dealing with

  4. services you are offering

  5. how you identify and communicate with your clients

  6. how your agency is structured (legal structure, human resources, location, operational resources)

  7. the number of transactions per year

  8. the unusual transactions (because of client behaviour, intermediaries involved, means of payment used)

This exercise should result in a score, showing either low, medium or high risk attached to these different indicators and your business as such.


Failing to comply with the obligation to carry out a business risk assessment may result in administrative sanctions (fines up to 1 million euro, withdrawal of the business permit) and even criminal sanctions (fine up to 5 million euros).


AML4YOU is offering a template business risk assessment, where you can tick boxes and give scores to the individual risk factors.


Check it out and download it under the following LINK.


If you would like assistance to validate this risk assessment you have done, you may book an appointment with one of our experts.


Book an online appointment HERE.





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