LBC/FT Compliance: Demonstrate mastery of your risks
ARCAD carries out audits, independent reviews and AML/CTF support services for professionals subject to Luxembourgish regulations on combating money laundering and the financing of terrorism.
In LBC/FT, compliance must be proven in fact.
Professionals subject to AML/CFT obligations must be able to demonstrate that their systems are actually working: global risk analysis, procedures, KYC files, controls, alerts, escalations, decisions, and remediation actions.
Audit, strengthen and update your AML/CFT framework methodically.
ARCAD examines the design of the AML/CFT device, as well as its practical application: quality of KYC files, consistency of classifications, relevance of controls, alert processing, documentation of decisions, and follow-up of identified weaknesses.
Depending on your needs, ARCAD can also assist with remediation: updating or drafting AML/CFT procedures, formalising the global risk analysis, supporting Compliance Officer missions and updating KYC files.
A comprehensive review of the key components of your AML / CFT compliance.
The scope is adapted to your business, your risk exposure, your organisation, your customer base and the maturity level of your system.
LBC/FT Governance
Review of roles, responsibilities, governing bodies, reporting lines, committees, escalations, and key decision documentation.
AML/CTF Global risk assessment
Review or formalisation of the overall anti-money laundering (AML) and counter-terrorist financing (CTF) risk assessment, based on your activities, your client base, your distribution channels, and your geographical exposure.
KYC and due diligence
Review and update of client files, collected information, supporting documents, due diligence, enhanced due diligence and periodic reviews.
Screening for sanctions, PEPs and adverse media
Analysis of the screening process, alert handling, decision justification and associated documentation.
Procedure, controls & escalations
Review, drafting or updating of the AML/CFT procedure, first and second level controls, escalation mechanisms and traceability.
RC & remediation missions
Support for risk control missions, preparation of the control plan, monitoring of findings, prioritisation of recommendations and support during remediation.
A structured method: interviews, tests, documentation and exception analysis.
The work is conducted within a clear framework, with particular attention paid to the quality of evidence, the consistency of decisions, and the traceability of the system.
Scope
Definition of the scope, populations to be reviewed, processes concerned, stakeholders and documents to be collected.
Documentary review
Analysis of policies, procedures, controls, reporting, committees, tracking files, risk methodologies, and governance elements.
Tests & Interviews
Review of samples, interviews with relevant departments, case analysis, alert processing and identification of exceptions.
Remediation
Formalisation of findings, risk qualification, prioritised recommendations and support with necessary updates.
Transform AML findings into concrete, documented actions.
The value of an AML/CFT review doesn't stop at the report. ARCAD can support the necessary upgrade work to strengthen the consistency, documentation, and operational effectiveness of your strategy.
This support can be ad-hoc or recurring, particularly in the context of AML missions, KYC file updates or LBC/FT documentation formalisation.
AML/CTF procedure
Drafting, reviewing or updating the procedure to reflect applicable obligations, responsibilities, controls and practices.
Global Risk Analysis
Structuring or updating the comprehensive analysis of AML/CFT risks, taking into account your activities, clients, products, channels, and geographical areas.
RC Missions
Support for the RC in preparing the control plan, carrying out assignments, documenting findings, and reporting.
KYC files
Support for updating KYC files, document collection, individual risk analysis and processing of missing items.
VIGIL, a comprehensive app for structuring your KYC, AML, and Risk management processes.
ARCAD relies on VIGIL to support its AML/CFT work: centralisation of KYC files, screening, risk analysis, documentation of decisions, monitoring of controls, and production of reporting.
The app does not replace human expertise or the responsibility of the relevant bodies. It provides a structured framework for better documenting, tracking, and managing actions related to AML/CFT compliance.
Centralised KYC files
Group information, documents, validations, and histories in a structured environment.
Country risk screening
Support for sanctions, PEP, adverse media and geographic risk checks in KYC processes.
RC Controls & Recommendations
Formalise missions, track findings, manage recommendations, and produce actionable reports.
Traceability & reporting
Strengthening decision documentation, the audit trail, and governance visibility.
Moving from what is claimed to what can actually be demonstrated.
An AML/CFT device must be understandable, applicable, testable, and justifiable. ARCAD helps to identify discrepancies between the formal framework, actual practices, and available documentation.
The review helps to improve the clarity of the system, the quality of the files, the traceability of decisions, and the ability to manage corrective actions.
Consistency of classifications
Verify that the assigned risk levels are justified, documented, and aligned with available information.
KYC File Quality
Identify missing documents, outdated information, inconsistencies, or insufficiently formalised periodic reviews.
Alert processing
Review the management of sanctions, PEP, and adverse media alerts, as well as the justification for closures or escalations.
Remediation tracking
Transforming findings into followed-up, prioritised, and documented actions over time.
Clear deliverables for decision-making, prioritisation, and tracking.
The value of an AML/CFT audit hinges on the clarity of its findings, the accuracy of its recommendations, and the ability to track remediation over time.
- AML / CFT audit report structured with findings, risks and recommendations.
- Governance, roles, responsibilities, and escalation mechanisms analysis.
- Review or update of AML/CFT procedures according to the defined scope.
- Global AML/CFT risk assessment or review of existing assessment.
- Results of KYC reviews, due diligence, enhanced due diligence, and periodic reviews.
- Analysis of sanctions, PEP, and adverse media screening processes.
- Prioritised action plan with recommendations, responsible parties and remediation deadlines.
A review suited to sectors subject to AML / CFT obligations.
ARCAD supports organisations and professionals who need to have a structured, applied, documented, and manageable AML/CFT framework in place.
Let's strengthen the AML/CFT compliance and traceability of your device.
Do you wish to review your LBC/FT governance, update your procedure, formalise your overall risk assessment, support your RG missions, update your KYC files or structure a remediation plan? ARCAD can support you with an independent, methodical and action-oriented approach.
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