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Courses/ AML/CFT/ Module 5/ Lesson 5.3
Lesson 3 of 3 · Module 5

A confirmed match, and what happens next

Freeze, do not make funds available, notify the Ministry of Finance, and never release on your own authority. Where the sanctions obligation ends and the article 5 obligation begins.

3:15 Module 5. International financial sanctions 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 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 5 covers

Module 5. International financial sanctions

Why a prohibition is not calibrated to risk and which authorities sanctions put you in front of under the Law of 19 December 2020, the screening framework made explicit by Circular CSSF 25/896 and the EBA guidelines applicable since 30 December 2025, the discipline of resolving hits rather than reducing them, and what a confirmed match obliges you to do: freeze, do not make funds available, notify the Ministry of Finance, and never release on your own authority.

Sources for this lesson

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

The freezing obligation and the prohibition on making funds or economic resources available run from the EU regulations themselves, of which Council Regulation (EU) 269/2014 is the one most often met in practice. The notification goes to the Ministry of Finance under the Law of 19 December 2020, and any release from frozen assets requires an exceptional authorisation from the Ministry. None of that displaces article 5 of the Law of 12 November 2004.

The rest of Module 5

Module 5. International financial sanctions

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