CSSF de-risking communique: managing ML/FT risk instead of avoiding it, what Luxembourg-regulated firms must address in their AML/CFT frameworks
A relationship manager flags a client as awkward. The country profile is messy, the ownership chain runs through two jurisdictions, and the file would take real work to keep current. The easy answer is to exit. Close the account, decline the onboarding, and the risk number on the dashboard goes down. The CSSF communique of…