CSSF Imposes Fine For AML And Sanctions Compliance Violations

In an Administrative Sanction published by Luxembourg’s CSSF, a fine of €56,000 was imposed on Stonehage Fleming Luxembourg S.A.

Most of the notice relates to AML compliance failings, but included was a complaint as regards to the resolution of sanctions screening hits and a delay in implementing changes to lists for screening purposes:

“At the time of the on-site inspection, hundreds of name screening alerts had been treated with significant delays and 42 alerts remained unnoticed by the PFS. These delays constitute a breach of the obligations foreseen in Article 3(2) point (d) of the AML/CFT Law and in Article 33(1) of CSSF Regulation No 12-02, as the PFS was unable to identify “without delay” persons subject to restrictive measures in financial matters and therefore apply “without delay” potential restrictive measures in financial matters as the case may be“.