In order to further strengthen their collaboration in the fight against money laundering and the financing of terrorism, the Luxembourg Bankers’ Association (ABBL), the Cellule de Renseignement Financier (CRF) and the Commission de Surveillance du Secteur Financier (CSSF) have signed a Public Private Partnership on 13 September 2022.
The fight against ML/TF requires an integrated approach in which public authorities and industry representatives pool their knowledge and skills to prevent, detect and combat these crimes together. Such a public-private dialogue helps providing clarity on risks related to specific activities, typologies of crimes, regulatory expectations, and also aims at identifying specific areas or issues where more regulatory guidance is needed.
Taking these challenges into consideration, ABBL’s CEO Jerry Grbic, CRF’s Director Max Braun and CSSF’s Director General Claude Marx have signed on 13 September 2022 the new terms of reference applicable to a revamped public-private exchange platform of the banking sector in Luxembourg.
This signature is the culmination of a procedure launched three years ago. In the course of the year 2019, the ABBL’s Private Banking Cluster became associated to the process initiated by the CSSF and four working meetings between the CSSF and the ABBL were organized.
On 1st December 2019, the CSSF published the first Private Banking Sub-Sector Risk assessment in Luxembourg.
In 2020, a permanent joint Expert Working Group on ML/FT risks in Private Banking was created with representatives of the Private Banking sector, the ABBL, the CRH and the CSSF. The first meeting took place on 25 February 2020 and meetings continued on a regular schedule afterwards to discuss topics that are relevant to ML/FT prevention in Private Banking.
The need to enlarge the discussions to banking in general progressively arose and in 2022, the members of the Expert Working Group decided to create an overarching Expert Working Group on ML/FT risks in the banking sector in Luxembourg, called Expert Working Group - Compliance. It will be made up with Chief Compliance Officers of the banking sector in Luxembourg, representatives of the ABBL, the CSSF and the CRF.
As from this date, the public-private platform will operate through the Expert Working Group – Compliance and the Expert Working Group – Private Banking will constitute a sub-group.
Picture (from left to right):
Jerry Grbic, CEO ABBL I Catherine Bourin, Member of the Management Board, ABBL I Claude Wampach, Director CSSF in charge of banking supervision I Claude Marx, Director General CSSF I Anouk Dumont, Deputy Director CRF I Max Braun, Director CRF.