Publication of the update of the Private Banking Sub-Sector ML/TF Risk Assessment

With assistance from the members of the Expert Working Group on Private Banking (EWG PB), which includes representatives of the private banking sector, the ABBL, the FIU and the CSSF, the CSSF has updated its Private Banking Sub-Sector Risk Assessment (PBSSRA) of 2019.

Since the publication of the first PBSSRA, Luxembourg has made several important publications relating to AML/CFT. A revised National Risk Assessment of Money Laundering and Terrorist Financing and a Vertical Risk Assessment on Virtual Asset Service Providers were published in 2020. Furthermore, a Vertical Risk Assessment on Legal Persons and Legal Arrangements and a Vertical Risk Assessment on Terrorist Financing were published in 2022.

Drawing on the experience gained from these assessments, as well as the FATF Mutual Evaluation Report of 2023, the CSSF has now reviewed and updated the PBSSRA. The 2023 PBSSRA update includes several new sections (e.g. on the terrorist financing risk in private banking as well as new or developing risks) and provides updated recommendations to the private banking sub-sector.

The CSSF expects all supervised entities engaging in private banking activities to integrate the findings, conclusions and recommendations resulting from this sub-sector risk assessment into their AML/CFT frameworks to ensure they remain appropriate to effectively mitigate ML/FT risks.