The Luxembourg financial regulator, the Commission de Surveillance du Secteur Financier (CSSF) released guidance on the implications of COVID-19 for AML/CFT risks, and mitigating actions. It also outlines CSSF’s approach to AML/CFT supervision.
CSSF highlights insider trading and marking manipulation as particular risks, along with cyber risks including fraud and data theft.
CSSF advises AML/CFT professionals to check in with their business and remind them of current risks and obligations. CSSF suggests new ways may be used to identify and verify customers, but reminds professionals that GDPR must still be taken into account.
The guidance also includes a useful illustrative scenario and risk assessment 'quiz' to help regulated entities assess impacts.
On 1 April 2020, the FATF President released a public statement regarding Covid-19 and measures to combat laundering and illicit financing. In this statement the FATF President drew the attention of the professionals and the regulators to the new challenges entailed by the outbreak. The CSSF published Circular CSSF 20/740 to provide Luxembourg professionals with information particularly relevant for their activities and to provide guidance on how to abide by AML/CFT professional obligations during this crisis.