Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF)

Anti-Money Laundering and Counter Terrorist Financing

KPMG Forensic’s AML & CTF team is uniquely placed to assist professionals in protecting themselves against criminals

KPMG Forensic’s AML & CTF team is uniquely placed to assist professionals in protecting...

Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) remain high on professionals’ agendas, given increased regulatory attention on tax transparency and tax evasion. Indeed, tax crime has been established as a predicate offence, a circular (17/650) has been released by the CSSF and FIU, and KYC and governance frameworks are continually in the spotlight. The 4th AML Directive has just been transposed into national law and will shortly be amended by the 5th AML Directive—and further ahead, of course, will come the 6th AML Directive.

Failure to comply can result in massive regulatory fines (up to millions of euros), not to mention reputational damage.

To protect themselves against criminals and to comply with highly keen regulators, professionals must install robust, effective, and sustainable frameworks and dedicate the appropriate resources and measures to mitigate identified risks. This means identifying and prioritising improvements to their compliance activities, enabling more efficiency and agility. For some, technology solutions could help automate critical areas and improve internal data circulation. Others may want to enhance manual processes to achieve a more consistent, repeatable, and sustainable approach to AML/CTF, sanctions, and tax regulatory changes.

KPMG has extensive experience in assisting professionals in their AML/CTF journeys, helping turn compliance from burden into competitive edge and enabling greater program agility, effectiveness, efficiency, sustainability, and integration.

We can help you identify and assess risks, as well as conduct investigations, remediation, and operational transformations related to a wide range of financial crime issues like anti-money laundering, sanctions, counter terrorist financing, and tax evasion. We can design and implement new operating models, help prevent past problems, design and test controls, and help transform the culture and capability of the organisation.

KPMG works with professionals from the banking, asset management, and insurance sectors who must fulfil the same AML/CTF regulatory requirements, but who face somewhat different challenges and market practices.

Our professionals operate globally, drawing on a huge network of expertise.


Our services

AML & CTF Compliance Assistance
The need for effective AML/CTF compliance programs, systems, and controls is well known, as are the severe penalties for firms failing to comply.
KPMG has provided AML/CTF compliance assistance worldwide, and has contributed to some of the largest AML investigations and program rehabilitations in recent history. Whether assisting a financial institution proactively seeking to improve its program or reactively responding to a regulatory order, we can:

  • assess your current AML/CTF framework (including oversight controls and monitoring activities) and review and/or design your policies and procedures
  • assist professionals in their AML/CTF (including FATCA/CRS and tax compliancy) risk assessment of their activities and enable them to properly mitigate the risks identified
  • assist professionals in the design and implementation of a risk-based approach
  • assist professionals in demonstrating to third parties the adequacy of their AML/CTF policies and procedures and controls by providing assurance-related and factual reporting
  • assist and support the Compliance Officer and other professionals in addressing any specific AML/CTF matters or needs

Customer / distribution / transaction / due diligence
The customer due diligence obligations that come with new business relationships have intensified, and will continue to do so following upcoming regulations. These “Know Your Relationship” obligations (i.e. “Know Your Customer”, “Know Your Intermediary”, “Know Your Distributor”, “Know Your Counterparty”, “Know Your Transaction”) are applicable throughout the entire relationship, requiring professionals to update obtained information and documentation on a regular basis.

KPMG can help you with:

  • the review of specific relationships (customers, distributors, transactions, high-risk cases, etc.)
  • assessing the AML/CTF legislation in the countries where you want to have relationships, enabling you to identify/mitigate gaps and risks vis à vis the Luxembourg legislation
  • the due diligence of your distribution network (gap analysis of the AML/CTF distributor’s policies and procedures with the Luxembourg AML/CTF legislation, distributor’s country risk assessment)
  • conducting an integrity due diligence investigation on related party/customer/prospect/etc. using KPMG’s own integrity tool (Astrus)
  • implementing and conducting an AML remediation plan and program (that also includes FATCA/CRS/tax-compliancy aspects)
  • assessing of the adequacy of an entire relationship portfolio transferred as part of a migration of fund (pre- to post-migration phases), in the frame of a business deal (buying or selling business)


Transaction/Sanction Monitoring
KPMG can help you with:

  • the assessment of your existing monitoring systems, i.e. transaction monitoring, sanction, and PEP screening tools by reviewing scenarios, parameters, and thresholds considering your business activities and customers
  • the implementation of robotic process automation and machine learning in order to improve the efficiency of your current monitoring tools
  • selecting and implementing monitoring tools

AML/CTF regulatory training and update

Legally, employees must participate in training every year. KPMG can help by providing training sessions, from refresher courses to more detailed and tailor-made training workshops. We can hold workshops specially for the Board of Directors, for example, or for the compliance staff. We can help design training materials and programs as well.

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