AML & KYC - GAP Analysis
Ensuring adherence to anti-money laundering and counter-terrorism financing regulations, commonly referred to as AML/FT, is a critical aspect of your day-to-day responsibilities.
Ensuring adherence to anti-money laundering and counter-terrorism financing regulations, commonly referred to as AML/FT, is a critical aspect of your day-to-day responsibilities.
Sanctions for regulatory or legal infractions include warnings, public statements, suspension or revocation of your authorization, as well as fines.
Who is impacted ?
✓ Financial professionals subject to CSSF supervision, such as Management Companies, AIFM, credit institutions, SIF, UCITS, SICAR, payments institutions, central administrators ...
✓ Financial professionals subject to AED supervision such as RAIF
✓ Insurance undertakings licensed or authorized to exercise their activities in Luxembourg as well as the professionals of the insurance sector
✓ Family offices
✓ Other professionals (mainly accountants, real estate agents, notaries, lawyers)
What are the main obligations ?
✓ Perform an AML risk assessment
✓ Perform a country risk assessment
✓ Carry out customer due diligences (on investors and counterparties)
✓ Implement policies and procedures
✓ Report suspicious activities
✓ Receive regular training
How can Osmia Consulting assist you ?
Assess your AML-KYC risk by conducting a gap analysis
Train your teams on AML-KYC topics
Stay informed about any new regulatory and legal developments
Keep your policies and procedures up-to-date
Organize your due diligences in an efficient way
RC – RR – find your MLRO or responsible officer
RCS – New requirement
As of 12 November 2024, all natural persons who are already or will be registered in the Luxembourg Trade and Companies Register (RCS) must provide their Luxembourg National Identification number (LNIN). If they do not have a LNIN, they must obtain one.
Luxembourg National Identification Number
As of 12 November 2024, all natural persons who are already or will be registered in the Luxembourg Trade and Companies Register (RCS) must provide their Luxembourg National Identification number (LNIN). If they do not have a LNIN, they must obtain one.
The LNIN, also known as the 'matricule number' or the 'CNS number', is a unique identifier for natural persons. It is automatically assigned to Luxembourg residents and Luxembourg workers.
Who is impacted by this ?
All natural persons registered with the RCS, in any capacity
Shareholders, Partners, Directors, Managers, representatives and auditors.
What are the obligations of natural persons who do not have a LNIN yet ?
Fill in a specific filing form on the RCS portal by communicating:
First names; Last name; Date, place and country of birth; Gender; Nationality; Private home address (number, street, postal code, locality, country); Supporting documents such as ID documents and proof of private address, everything translated into English or one of the national languages.
What are the obligations of natural persons in possession of a LNIN ?
Fill in a specific filing form on the RCS portal for this purpose, allowing the communication of the LNIN.
What is the impact of non-compliance ?
Inability to finalize filing procedures with the RCS, no matter if it relates to a natural persons or not (e.g. filing of annual accounts).
How Osmia Consulting can help you ?
Conduct a gap analysis to evaluate your impact
Fill in the required forms
Keep your LNIN request up-to-date