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By Nicolas MARINIER, Partner and Emilie RUBAYIZA, Manager, Deloitte Luxembourg
Some market players argue there is no hard deadline for contacting the Luxembourg Financial Intelligence Unit (FIU) or the Ministry of Finance (“the Ministry”) in due time.
However, the term “without delay” is critical for authorities. Given the speed of international wire transfers, timing is essential for authorities to investigate and act before the funds have vanished from their jurisdiction. So, what does “without delay” mean regarding your Anti-Money Laundering and/or Counter-Terrorist Financing (AML/CTF) obligations?
Sanctions screening
When it comes to sanctions screening, the term ...
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