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Courses/ AML/CFT/ Module 3/ Lesson 3.1
Lesson 1 of 5 · Module 3

The risk based approach, and what you must be able to show

A risk based approach is a document you can produce, not an attitude you can state. The four questions an inspector asks of it, in the order they are asked.

2:58 Module 3. KYC and due diligence in practice AML/CFT and KYC in Luxembourg practice
The video and the full transcript of this lesson are part of the course This page is the description of the lesson: what it is about, how long it runs and every instrument it is built from. Watching it and reading it word for word need an account with access to AML/CFT and KYC in Luxembourg practice. Two lessons of this course are open to everyone with no account and no payment.
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The course30 lessons across 7 modules, each with its transcript and its sources
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  • Every claim linked to its primary source, with a source register per lesson
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  • The downloadable artefacts and one page references for this course

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The narrated video runs about 1 hour 31 minutes across the 30 lessons. That is short on purpose: no filler and no reading out of the law, with the work in the transcripts, the sources, the assessments and the artefacts.

What Module 3 covers

Module 3. KYC and due diligence in practice

The risk assessment you have to be able to produce and the four questions an inspector asks of it, identification of a customer and of the ownership and control structure behind it, the beneficial owner and the register with the duty to report discrepancies, source of wealth against source of funds for politically exposed persons, and due diligence on the asset as well as on the investor.

Sources for this lesson

Every instrument this lesson is built from, linked to its official text

Article 2-2 of the Law of 12 November 2004 is the entity obligation to carry out a risk assessment; article 2-2(2) requires the risk information in the national and supranational risk assessments, or communicated by the supervisory authorities, the self-regulatory bodies or the European supervisory authorities, to be integrated into it, and requires the assessment to be documented, kept up to date and made available to the supervisor. The risk assessment articles of CSSF Regulation 12-02 carry the operational detail, and the Grand-ducal Regulation of 1 February 2010 carries the risk factors and the circumstances triggering simplified or enhanced measures. The EBA risk factors guidelines are applied in Luxembourg by Circular CSSF 25/878 of 7 April 2025, which adopts the amending guidelines EBA/GL/2024/01 amending EBA/GL/2021/02, and complements Circulars CSSF 23/842 and 21/782. Article 9-1quinquies, inserted by the Law of 16 July 2026, governs the national assessment by the Comite de prevention and imposes nothing on the entity.

The rest of Module 3

Module 3. KYC and due diligence in practice

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