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Podcast #2: AML/CTF – Recent Luxembourg developments: extraterritorial effects of the AML Act 2004

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Thomas Berger



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Aubry Baptiste
Baptiste Aubry

Head of Finance regulatory


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10 September 2020

A common misconception often leads to the beliefbelieve that the AML Act 2004 only covers the Luxembourg territory and professionals established in Luxembourg. 

This is, however, not entirely accurate and some recent clarifications made in the AML Act 2004 while implementing 5MLD are a good opportunity to look at the extraterritorial effects of the Luxembourg AML/CTF framework on branches and subsidiaries of Luxembourg professionals as well but also on foreign professionals providing cross-border services in Luxembourg.

The A&O AML/CTF experts shed some light on this regime, its impact on obliged entities in scope and the particular measures to apply where high-risk countries are in the picture.


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