AML/CFT In Luxembourg During The COVID-19 Crisis

In Circular 20/740 ¹ of 10 April 2020, the Commission de Surveillance du Secteur Financier (the "CSSF") describes the money laundering and terrorism financing ("ML/TF") implications of the worldwide COVID-19 crisis for Luxembourg professionals under its supervision ("Professionals"), including credit institutions, investment fund managers and professionals of the financial sector (PFS). The CSSF stresses that, more than ever, Professionals must continue to comply with their anti-money laundering and counter-terrorism financing ("AML /CTF") obligations in accordance with the Law of 12 November 2004 on the fight against money laundering and terrorist financing, as amended (the "AML Law") during this crisis. Indeed, due to the extraordinary circumstances under which they are currently providing services, Professionals are exposed to particular forms of ML/TF threats they are neither used to nor particularly prepared to manage.