Clifford Chance

Coronavirus: Financial crime and AML/CTF implications

13 April 2020

On 10 April 2020, the CSSF issued a new Circular 20/740 to provide guidance in relation to the money laundering and terrorism financing (ML/TF) risks and AML/CTF implications of the Covid-19 pandemic. The CSSF notes that despite the economic downturn, illicit financial flows will continue and criminals and terrorists may seek to exploit temporary weakness in AML/CTF controls. The supervised professionals are therefore required to put in place and maintain effective systems and controls to ensure that Luxembourg's financial system is not abused for ML/TF purposes. The new circular provides guidance in this context for the CSSF-supervised professionals on new and emerging ML/TF threats, possible areas of particular vulnerability, the mitigating actions as well as the AML/CTF supervision during this period

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