On March 16th 2015, the Financial Intelligence Unit ("FIU") of Luxembourg issued a new form to file suspicious transaction reports ("STR"). The Anti-money laundering Law of November 12th 2004 includes the obligation, for the subjected professionals, to inform without delay, on their own initiative, the FIU when they know, suspect or have reasonable grounds to suspect that money laundering or terrorist financing is being committed or has been committed or attempted, in particular in consideration of the person concerned, its development, the origin of the funds, the purpose, nature and procedure of the operation. This report must be accompanied by all supporting information and documents having prompted the report.
A writable PDF is made available in lieu of the template provided by the FIU when it issued circular 22-10. The content is essentially the same as for the initial document.
From now on, the STR itself has two new appendices, one dedicated to Legal Persons (LP) and another to Natural Persons (NP), to inform about the particulars of the persons subject to the suspicion or simply involved in the relationship with the professional who has a suspicion to report. One has to fill in (only in French) as many appendices as there are number of related persons.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.