Luxembourg – CSSF imposes €785,000 fine for sanctions compliance failings

The Luxembourg financial services regulator, the CSSF, has today published a report of an administrative penalty imposed on Fuchs & Associés Finance SA.

The fine was €785,000.

Some of the compliance failings relate to AML and KYC more generally, and some were specific to sanctions. The sanctions-specific failings were:

      • “name screening controls aiming at detecting persons subject to prohibitions and restrictive measures in financial matters had not been carried out for all clients of the trading desk, as their names were not
        included in the databases used to feed the name screening systems”;
      • “the name screening tools were updated only once a week, and
        no additional controls were in place, particularly when new European and United Nations lists are issued”; and
      • “the absence of a complete and exhaustive client database”.

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