Effective procedure for combating money laundering in real estate

A procedure to combat money laundering in the real estate sector is a set of measures and policies implemented by real estate agencies, developers, notaries, and other professionals in the industry to identify, prevent, and report attempts of money laundering. This procedure is crucial due to the significant amounts involved in real estate transactions, which can be used to launder funds from illegal activities.

Importance of anti-money laundering procedure

• Crime prevention: It helps prevent the real estate sector from being exploited for money laundering from criminal activities such as drug trafficking, terrorism, and fraud.
• Market integrity: Maintains trust in the real estate sector by ensuring that actors operate within legality and transparency.
• Regulatory compliance: Ensures that businesses and professionals in the sector comply with current laws and regulations, thereby avoiding heavy fines and sanctions.

Key elements of an anti-money laundering procedure

• Customer Identification and Verification (KYC): Knowing the identity of customers, including beneficial owners, through official documents.
• Transaction monitoring: Reviewing transactions to detect those that appear unusual or without apparent economic justification.
• Staff training: Training employees to recognize signs of suspicious activities and the procedures to follow for reporting them.
• Record keeping: Keeping detailed records of transactions, identity verifications, and suspicious activity reports for a defined period.
• Suspicious activity reports: Reporting any suspicious activity to the relevant authorities without informing the concerned client.

The effective implementation of these procedures requires a coordinated approach involving all stakeholders in the real estate sector, as well as regular updates to address evolving money laundering methods and regulations. Ultimately, combating money laundering in real estate not only protects the sector against criminal abuse but also contributes to the overall fight against financial crime.

Demystifying AML/CFT jargon: Nextimmo's glossary for all

The fight against money laundering and terrorist financing (AML/CFT) is a complex field, woven with technical terms and dense legislation. Fortunately, Nextimmo Sàrl offers a procedures manual that includes a glossary to clarify each key concept clearly. Let's take a moment to decipher some of these essential terms.

The law: The foundation of the fight

The law of November 12, 2004, amended thereafter, constitutes the legal basis for combating money laundering and terrorist financing. It is the foundation upon which all Nextimmo actions rely to operate in a compliant and effective manner.

AED: The supervisory authority

The Administration of Registration and Domain is the watchdog entity. It ensures that professionals adhere to the obligations imposed by law, thus ensuring that AML/CFT measures are rigorously applied.

CRF: Financial detectives

The Financial Intelligence Unit plays a crucial role by acting as the central point for collecting and analyzing information related to money laundering from the Luxembourg Public Prosecutor's Office.

AML/CFT: Two acronyms, one battle

These terms refer to the efforts deployed to prevent and combat money laundering and terrorist financing, an absolute priority for Nextimmo.

FATF: The international watchdog

The Financial Action Task Force is an intergovernmental organization that establishes international standards and promotes the effectiveness of AML/CFT measures worldwide.

PEP: High-risk profiles

Politically Exposed Persons pose higher risks due to their ability to influence or access public funds, requiring increased vigilance.

Clarity and compliance: The watchwords

This glossary is not only a tool for understanding complex terms; it is an integral part of a broader approach to ensure clarity and compliance in all Nextimmo operations.

In summary, these terms are the pillars of the fight against financial crimes that can affect the global economy. Through manuals such as this one, Nextimmo Sàrl paves the way for better understanding and more effective action for all stakeholders in the financial sector.

Understanding Nextimmo's commitments in the fight against money laundering and terrorism financing

In today's professional world, regulatory compliance is a crucial component of a company's reputation and success. Nextimmo Sàrl, a proactive real estate agency, is no exception to this rule. Their recently published procedures manual highlights the company's commitment to meeting legal and ethical obligations in the fight against money laundering and terrorism financing (AML/CFT).

Objective of the procedures manual

Nextimmo takes its responsibility to prevent illegal activities seriously. The procedures manual clarifies the professional obligations of Nextimmo and its employees, including real estate agents and independent professionals working under their name. This document specifically focuses on real estate transactions where the monthly rent exceeds 10,000 euros, recognizing the increased risks associated with such significant sums.

Scope of the procedure

The implementation of this procedure is not limited solely to Nextimmo's internal operations but also extends to all its clients. This demonstrates Nextimmo's commitment to promoting a healthy and transparent financial environment, not only internally but also in its interactions with the external world.

Legal and professional framework

The manual cites several essential European laws and directives that form the regulatory framework of AML/CFT. Among these, Directive (EU) 2018/843 aims to prevent the abuse of the financial system for criminal purposes. It is complemented by Directive (EU) 2015/849, which strengthens vigilance measures, and the law of November 12, 2004, which ensures the transposition of European directives into the Luxembourg context.

These legal references are not just guidelines for Nextimmo; they reflect the commitment of the European Union and its member states to collectively combat these financial scourges.

Conclusion: The creation of this manual by Nextimmo Sàrl perfectly illustrates how companies can and should align with current regulations to combat financial crimes. It is an approach that strengthens the trust of clients and partners while ensuring the protection and integrity of the global financial system.

Regulatory foundations of money laundering prevention at Nextimmo

The fight against money laundering is not merely about good intentions; it's about rigorous compliance with constantly evolving regulations. At Nextimmo, a series of legislative texts and guidelines frame this battle against financial crime. In our latest procedures manual page, we uncover the pillars of this regulation.

Key regulations

The Grand-Ducal Regulation, updated in February 2010, and Circular AED 792 are two reference texts specifying the details of the law of November 12, 2004. They reinforce the obligation of customer identification and verification for professionals, including real estate agents, thus emphasizing the importance of transparency.

Directives and professional ethics

The CRF directive and the Code of Ethics of the Luxembourg Chamber of Real Estate Professionals are mentioned as standards of conduct and procedure to be followed, ensuring that real estate transactions take place under the strictest ethical norms.

The influence of FATF

The Financial Action Task Force (FATF) is cited for its global recommendations on combating money laundering and terrorism financing. FATF-GAFI reports provide an international perspective and methodologies to assess and mitigate associated risks.

The nature of money laundering

It is essential to recognize that money laundering is always linked to underlying crimes such as drug trafficking, human trafficking, or sexual exploitation. These illegal activities generate profits that, if left unchecked, can infiltrate and corrupt the legitimate economy.

Conclusion: By incorporating these regulations into its procedures manual, Nextimmo demonstrates its serious commitment to protecting the economy against the threats of financial crime. It is a clear commitment to financial security that transcends the boundaries of the company to impact society as a whole.

The implications of money laundering and terrorism financing in real estate transactions

In the real estate industry, vigilance is not an option but an obligation. Nextimmo Sàrl, aware of this responsibility, tackles the challenges posed by money laundering and terrorism financing, activities that threaten global security and economic integrity.

Crimes associated with money laundering

The list of primary offenses linked to money laundering is long and sordid, including drug trafficking, tax fraud and evasion, corruption, and many others. All these criminal acts generate illicit profits that need to be "cleaned" to enter the legal financial system. Nextimmo takes these crimes very seriously because their association with real estate transactions can be not only harmful but also criminal.

Terrorism financing: A global concern

Terrorism financing, defined as the deliberate provision of funds for terrorist acts, is a major concern. Nextimmo is committed to ensuring that its transactions do not serve as channels for such activities. This involves thorough analysis of funding sources and constant monitoring of transactions to prevent abuse.

The concept of "Ultimate beneficial owner"

The law requires entities, such as Nextimmo, to identify the "ultimate beneficial owner" in any transaction. This term refers to the natural person who ultimately owns or controls an entity and for whom a transaction is conducted. For companies, this means an individual owning more than 25% of shares or having significant control. This transparency is essential to prevent real estate from becoming tools for money laundering or terrorism financing.

Conclusion: At Nextimmo, rigorous due diligence processes and ultimate beneficial owner identification are not mere formalities but essential measures to ensure financial security. Combating money laundering and terrorism financing is a top priority that requires constant vigilance and proactive action.

The art of due diligence: Identifying ultimate beneficial owners and PEPs at Nextimmo

At the core of real estate operations lies a crucial step often overlooked by the general public: the identification of Ultimate Beneficial Owners (UBOs) and Politically Exposed Persons (PEPs). At Nextimmo Sàrl, this is a practice ingrained in routine, essential to ensuring transaction integrity. But what does it entail in concrete terms?

The hunt for ultimate beneficial owners

An ultimate beneficial owner is the person who ultimately owns or controls a legal entity. Nextimmo not only adheres to this rule but applies it with exemplary rigor, seeking out not only those who hold more than 25% of shares but also those who exert dominant influence, even through indirect means. This could be through contractual agreements or complex management structures, such as trusts or fiduciaries.

The case of trusts and fiduciaries

In more opaque structures like trusts and fiduciaries, Nextimmo takes care to identify all involved parties: settlers, trustees, protectors, and most importantly, ultimate beneficiaries. This process ensures that the money in circulation is clean and that ownership is legitimate.

PEPs: A high-risk category

PEPs are individuals who hold or have held significant public functions, exposing them to increased risks of corruption and money laundering. Nextimmo treats these clients with particular attention, in accordance with applicable laws, to prevent potential abuse of their position or relationships.

Conclusion: Through these measures, Nextimmo Sàrl demonstrates that transparency is not just a matter of legal compliance but a cornerstone of professional ethics. It is with this meticulousness that the company builds trust with its clients and partners, thereby contributing to the overall fight against financial corruption.

Due diligence at Nextimmo: Focus on politically exposed persons (PEPs) and their families

When it comes to high-level real estate transactions, Nextimmo Sàrl's vigilance extends beyond the direct actors of the transaction. It encompasses a broader network of influential individuals and their close associates, commonly known as Politically Exposed Persons (PEPs).

Who are PEPs?

PEPs are individuals who hold or have held significant public functions, not only at the national but also international level. Nextimmo Sàrl recognizes that PEP status can increase the risks of corruption and money laundering, hence the importance of precisely identifying them. The list of PEPs includes heads of state, senior government officials, judges of supreme courts, ambassadors, high-ranking military officers, and even leaders of political parties.

Family and associates of PEPs

Attention is also paid to the entourage of PEPs: spouses, children, parents, and even siblings. Nextimmo Sàrl is aware that close families and associates can be used to bypass controls and facilitate dubious transactions.

Nextimmo's commitment

Without prejudice to enhanced vigilance measures, Nextimmo is not obliged to consider as PEP an individual who has not held a significant public function for more than a year, unless specific risks persist. This is an important distinction that balances the imperatives of privacy with those of preventing financial crime.

Conclusion: By integrating the principles of extended due diligence to PEPs and their family circles into its processes, Nextimmo Sàrl demonstrates its determination to operate within the bounds of legality and morality, thereby strengthening trust in the real estate industry and contributing to the global fight against corruption.

Nextimmo and the fight against money laundering: Rigorous risk management and the role of the LBC/FT officer

Within Nextimmo Sàrl, the fight against money laundering and terrorism financing (AML/CFT) is not confined to isolated actions; it's an ongoing mission that requires the establishment of key roles and precise procedures.

Identification of close associates of PEPs

Nextimmo's diligence extends beyond Politically Exposed Persons (PEPs); it encompasses individuals closely associated with these PEPs, including ultimate beneficial owners acting in concert with them. These measures aim to prevent the abusive use of financial networks by individuals close to centers of power.

The key role of the LBC/FT officer

Essential to Nextimmo's compliance framework, the Anti-Money Laundering/Counter Financing of Terrorism (AML/CFT) Control Officer is entrusted with oversight and control. This strategic position, reporting directly to management, ensures the independence and objectivity necessary for the effectiveness of preventive measures. Their appointment and any changes to this position are recorded via the goAML tool, ensuring absolute traceability and transparency.

A risk-based approach

The law requires Nextimmo to assess risks related to the company's activities and those of its clients. This analysis is based on various factors, including the nature of products and services offered, geographical aspects, types of clients, and the nature of transactions. It's a holistic approach that allows Nextimmo to calibrate its control measures according to actual risks.

Conclusion: Through the application of these principles, Nextimmo Sàrl demonstrates its commitment not only to complying with legal obligations but also to promoting a corporate culture firmly focused on ethics and financial responsibility.

This article highlights the rigorous framework established by Nextimmo Sàrl to ensure compliance with AML/CFT procedures. It underscores the importance of the role of the AML/CFT Control Officer and the risk-based approach guiding the company in its contribution to preventing money laundering and terrorism financing.

Nextimmo's onboarding process: AML/CFT prevention

Integrity in the real estate sector begins with a rigorous onboarding procedure. At Nextimmo Sàrl, this step is crucial to prevent money laundering and terrorist financing. Here's how Nextimmo manages its client onboarding with exemplary diligence.

Comprehensive risk assessment

Nextimmo goes beyond simply knowing its clients; it assesses and fully understands their activities, including risk factors such as the nature of their business and national risks. This assessment is constantly reviewed and updated, ensuring that the company stays abreast of changing sector dynamics.

Enhanced vigilance and information updates

The company ensures that client and beneficial owner identity information is regularly updated. Any significant changes must be communicated in writing by clients, a practice that maintains constant transparency between Nextimmo and its clientele.

First contact: Key moment for risk detection

From the first contact, Nextimmo engages in a thorough questioning process to detect any potential AML/CFT risk. This includes gathering information about the client's personal situation and, if necessary, requesting certified identity documents.

Nextimmo's onboarding procedure

Nextimmo applies a series of due diligence obligations upon welcoming a new client or reassessing an existing client. No business relationship will be established until identification and risk understanding procedures are complete and any suspicious transactions are resolved.

Conclusion: Nextimmo's onboarding process is a testament to their commitment to operate within legal and ethical boundaries. By adopting a risk-based approach and demanding full transparency from its clients, Nextimmo takes proactive measures to ensure the financial security of its operations and clients.

Key compliance steps at Nextimmo: Rigorous identification and monitoring

In the real estate sector, compliance with anti-money laundering and counter-terrorism financing regulations is crucial. Nextimmo Sàrl implements a meticulous process to ensure the traceability and legitimacy of each transaction. Here's how it works in practice.

Rigorous identification and verification

Every new contact at Nextimmo is welcomed with a rigorous identification process. A certified copy of the identity document is taken, and a mandate is signed. This is accompanied by thorough verification, where Nextimmo ensures that the names of clients and beneficial owners are not on sanctions lists or politically exposed persons lists.

Signing the sales agreement

Before a real estate transaction can be finalized, a sales agreement is prepared by Nextimmo. This ensures that all parties agree to the terms before committing.

Prospect monitoring

Nextimmo maintains a prospect tracking file for all its prospects, allowing for regular review and appropriate action for each case, whether it's following up with a prospect or offering additional services.

Transaction information collection

For each operation, Nextimmo collects detailed information to ensure transparency:

• For sales, this includes property description, cadastral data, plans, photos, and legal documents such as bank agreements and notarized deeds.
• For rentals, contracts, property descriptions, plans, and photos are collected.

Conclusion: This rigorous process illustrates Nextimmo's commitment to ensuring secure real estate transactions that comply with legal requirements. Rigor in information collection and client monitoring is the cornerstone of their compliance strategy.

Methods of client identification at Nextimmo: A compliance model

Customer knowledge is a cornerstone in the fight against money laundering and terrorist financing. Nextimmo Sàrl excels in this area by applying a detailed and meticulous identification process for each client, whether they are a natural person or a legal entity.

For legal entities

When it comes to businesses or other legal entities, Nextimmo collects essential information such as the name, legal form, registered office address, official identification number, and a list of directors. Required documents include articles of association, extracts from the commercial register, and a certified copy of a valid identity document for each authorized signatory.

For natural persons

Identifying individuals involves collecting personal data: name, gender, identity card number, nationality, address, and occupation. Required documents include a certified copy of the identity document, a recent utility bill to verify the address, and pay slips for those renting properties.

Documentary Rigor

Nextimmo does not settle for gathering this information; it requires official documents, often in the form of certified copies, to ensure the authenticity of the provided information.

Conclusion: Nextimmo Sàrl's identification process is a clear example of due diligence in the real estate sector. By diligently following these steps, Nextimmo enhances trust in its transactions and supports the fight against illegal financial activities.

Nextimmo Sàrl and customer identification: Procedures and exceptions

Customer identification is a standard procedure in many businesses, but at Nextimmo Sàrl, this step takes on a particularly rigorous dimension, especially in the context of remote transactions.

Remote document certification

For any remote business relationship, Nextimmo requires document certification by recognized authorities such as the police or embassies. For residents of the European Union, a certified identity card or passport is sufficient, while for residents of third countries, passport certification is required.

Multilingual understanding

Nextimmo ensures that any foreign identity document is at least in English, French, or German. If not, a sworn translation is requested, ensuring that all information is clear and understandable, regardless of the client's origins.

Additional measures and expedited procedure

As part of its risk assessment, Nextimmo may request additional documents. However, there is an expedited procedure for clients whose business relationship needs to be established exceptionally and quickly, provided that the risks of money laundering or terrorist financing are deemed low. In such cases, Nextimmo commits to completing the file within three months.

Exceptions to the rule

Nextimmo acknowledges certain exceptions to its identification requirement, notably for requests that do not aim to establish a business relationship or are deemed short-term, or when it is a first contact with the company without prior commitment.

Conclusion: These procedures demonstrate Nextimmo's commitment to compliance and the prevention of financial crime, while remaining adaptable to best serve its clients.

Defining the key moment: Business relationship establishment at Nextimmo

At Nextimmo Sàrl, operational clarity is essential. A crucial aspect of this transparency is determining the date of the establishment of a business relationship with the client. Here's how Nextimmo approaches this decisive step.

When does the business relationship begin?

The date of the establishment of a business relationship is a significant milestone for Nextimmo. It is defined as the moment when a client approaches the agency to entrust a sales or rental mission or to visit a property. This marks the beginning of a formal commitment and the commencement of due diligence procedures related to combating money laundering and terrorist financing.

Specific cases of business relationship establishment

Nextimmo specifies that the physical presentation of the client-buyer or tenant at the agency, or during a publicly announced collective visit, does not necessarily equate to a formal establishment of a business relationship. This important distinction helps avoid misunderstandings and ensures that all interactions are well-defined and compliant with regulations.

Enhanced due diligence regime

If at the time of establishing the business relationship, the information and documents necessary for the complete identification of the client are not provided, Nextimmo applies an enhanced due diligence regime. This process ensures that the company remains compliant with prevailing laws while safeguarding its operations against potential risks.

Conclusion: The precise determination of the date of establishment of a business relationship is a sign of Nextimmo's commitment to regulatory compliance and the prevention of financial risks. This clear policy not only defines Nextimmo's obligations but also sets expectations for its clients.

Risk analysis at Nextimmo: A personalized vigilance framework

Risk management is an essential component of compliance procedures at Nextimmo Sàrl, where a sophisticated risk assessment matrix is implemented for each client. Here's how Nextimmo adapts its vigilance measures to maintain the integrity of its operations.

The risk assessment matrix

This matrix, crucial to Nextimmo's procedure, considers various criteria such as Politically Exposed Persons (PEP), geographical origin, and the results of Name Screening. The latter is a process of verifying names against lists of sanctions, PEP, Interpol, among others. This analysis allows adjusting vigilance measures according to the assessed risk level.

Three levels of vigilance

1. Normal vigilance: Nextimmo proceeds with client and beneficial owner identification, documents the nature of the relationship, and ensures that operations are consistent with its understanding of the client.

2. Simplified vigilance: In certain situations, such as with financial institutions already subject to anti-money laundering legislation, Nextimmo may apply simplified vigilance measures.

3. Enhanced vigilance: If risks are deemed higher, Nextimmo strengthens its identification and monitoring processes.

Conclusion: With a rigorous and adaptable approach, Nextimmo Sàrl illustrates its commitment to operating within a secure framework, preventing money laundering and terrorist financing. The risk assessment matrix is a key tool that guides the company in applying appropriate vigilance measures.

Adaptation of vigilance measures at Nextimmo: A targeted and responsible approach

Nextimmo Sàrl does not merely apply uniform vigilance to all its clients; it adapts its measures based on the specific risk assessment of each situation.

Simplified vigilance for financial institutions and public entities

When the client is a financial institution or a publicly traded company, or is the beneficial owner of an account held by an independent legal profession, Nextimmo may apply simplified vigilance. This decision is based on the transparency and public accessibility of information regarding these clients, as well as the fact that they operate in jurisdictions subject to strict international standards for combating money laundering and terrorist financing.

Constant identification and reassessment

Nextimmo is committed to clearly identifying these clients and collecting the elements justifying simplified vigilance, ensuring that these conditions remain fulfilled over time.

Enhanced vigilance measures

There are circumstances that require Nextimmo to increase its level of vigilance. This may include cases where indicators of money laundering and terrorist financing risk are higher than normal, thus necessitating increased attention and control procedures.

Conclusion: By adjusting its vigilance measures according to the actual risks presented by each client, Nextimmo Sàrl demonstrates risk management that is both flexible and rigorous, enhancing transaction security while respecting regulatory requirements.

Nextimmo's validation of client relationships: Prudence and compliance

Nextimmo Sàrl implements strict measures to validate the establishment of relationships with its clients, a crucial step to ensure compliance with anti-money laundering legislation and the prevention of terrorist financing.

Validation criteria for the relationship

For each new client or transaction, the AML/CFT (Anti-Money Laundering/Combating the Financing of Terrorism) officer at Nextimmo ensures that the following conditions are met before validating the relationship:

• If the client is a Politically Exposed Person (PEP),
• If the client's or beneficial owner's country of residence poses a high risk,
• If the client is not physically present for identification,
• If the intended transaction is unusual,
• If the client is from a poorly regulated jurisdiction or listed by international organizations as being at risk,
• Or in any other situation where Nextimmo deems enhanced vigilance necessary.

Additional information and documents

The officer may also request additional information or specific reports, such as Enhanced Due Diligence (EDD) reports or Source and Use of Funds (SOUF) questionnaires, to deepen their risk analysis.

Strict Policy of Nextimmo

Nextimmo clearly states that it:

• Does not carry out cash transactions and accepts no exceptions to this rule,
• Considers a contract as valid only when all identification steps have been successfully completed, and the client has been accepted in accordance with legal obligations.

Conclusion: These procedures demonstrate Nextimmo's commitment to maintaining high standards of compliance and preventing financial crime, thus ensuring the security of operations and the trust of its clients.

Step by step: Nextimmo's decision-making process for establishing client relationships

Nextimmo Sàrl employs a structured decision-making process for establishing relationships with its clients. This process ensures that each new relationship is established with diligence and compliance. Here's an overview of the key steps that Nextimmo follows before accepting a new client or transaction.

Identification

It all starts with client identification. Whether it's an individual or a legal entity, Nextimmo conducts a thorough verification of the client's identity as well as beneficial owners and other related parties.

Documentation analysis

Once initial information is gathered, Nextimmo reviews the documentation and conducts analysis based on the risk assessment matrix. This step ensures that all aspects of the client relationship are in line with AML/CFT standards.

Complete file or missing documents

If the file is complete, Nextimmo can proceed with accepting the client. In cases where documents are missing, additional requests are made to the client.

Acceptance or refusal

The validation of the transaction by Nextimmo depends on obtaining all required documents. If necessary documents are not provided, it may lead to refusal, transaction blocking, or even suspicion reporting if necessary.

Conclusion: This process reflects Nextimmo's commitment to transparency and financial security. By following these steps, Nextimmo ensures that all its business relationships are based on clear understanding and mutual trust.

Security and compliance at Nextimmo: Constant vigilance and third-party engagement

At Nextimmo Sàrl, transaction security does not stop after establishing a relationship with a client. The company engages in constant vigilance, ongoing monitoring that ensures the integrity of its operations and regulatory compliance.

Constant vigilance at Nextimmo

• Nextimmo employees have a duty to report any complex operation or unusual transaction.
• The AML/CFT officer ensures that transactions are not linked to prohibited activities related to terrorist financing or international sanctions.
• Documents and data are regularly rechecked to ensure compliance with vigilance obligations.

Frequency of client file review

Nextimmo has established a review schedule based on risk level:

• Low risk: annual review
• Medium risk: every 6 months
• High risk: every 3 months each review results in a report signed by the AML/CFT officer and filed in the client's dossier.

Document update policy

Nextimmo has decided not to systematically update identification documents for low-risk clients, but it is rigorous for high-risk relationships, leveraging client meetings to update files as necessary.

Engagement of third parties

While Nextimmo directly handles its vigilance obligations, it may engage third parties for client identification. These third parties must meet legal requirements and promptly provide all information required by Nextimmo regarding clients, beneficial owners, and the nature of the business relationship.

Conclusion: This disciplined approach demonstrates Nextimmo's commitment to preventing money laundering and terrorist financing, ensuring continuous monitoring and collaborating with reliable partners when necessary.

Nextimmo's rigorous guidelines for combating money laundering and terrorist financing

At Nextimmo, the fight against money laundering and terrorist financing is taken very seriously. The company has implemented a series of strict procedures that demonstrate their commitment to compliance and prevention of financial risks.

Sanctions for non-compliance

Nextimmo follows a strict code of conduct where any failure to meet professional obligations can result in severe sanctions. These sanctions may include warnings, substantial fines, and even public disclosures revealing the identity of offenders and the nature of their violations.

"No tipping off" principle

To protect the integrity of investigations and prevention measures, Nextimmo adheres to the "no tipping off" principle. This means that the company cannot inform clients of the existence of suspicious reports or requests for information concerning them, except with specific authorization from competent authorities.

Training and continuous education

Nextimmo ensures that its staff are well-trained and informed about the latest regulations and practices in combating money laundering and terrorist financing. Ongoing training is a requirement for all staff, ensuring up-to-date vigilance and expertise.

Data archiving and protection

The company meticulously preserves all documents and information related to its clients, ensuring a complete and accessible history for any future verification or investigation.

Cooperation with authorities

Nextimmo works closely with Luxembourg authorities, following directives and promptly responding to any requests for information or actions related to suspicious operations.

Conclusion: The procedure implemented by Nextimmo reflects the rigor and seriousness with which the company approaches regulatory compliance. With constant monitoring and periodic controls, Nextimmo positions itself as a responsible player in the real estate sector, dedicated to maintaining financial integrity and preventing illegal activities.

Nextimmo's rigorous controls to prevent money laundering

In the fight against money laundering and terrorist financing, Nextimmo Sàrl spares no effort in control measures. Here's an overview of their methodical approach and the measures they take to monitor and secure each transaction.

Outsourcing and accountability

Nextimmo may choose to outsource some vigilance measures to third parties, but ultimate responsibility always remains with the company. This ensures that the most qualified experts perform these essential tasks while retaining final control over the process.

Nextimmo's range of controls

The AML/CFT officer at Nextimmo establishes a series of controls to assess the risk of laundering associated with each business relationship:

• Periodic verification: comparing client information with international sanctions lists.
• Transaction review: targeted sampling to assess risk based on amount, parties involved, and nature of the operation.
• Suspicious refund: analysis of unusual transactions such as excessively high refunds.

Specific risk indicators

The accounting department plays a key role in identifying complex or unusual transactions:

• Multiple or repeated transactions with small amounts.
• Transfers to or from high-risk jurisdictions.
• Interposition of individuals, often used to conceal the true identity of the beneficiary.
• Use of opaque financial intermediaries or informal networks.
• Transactions via fictitious banks or anomalies in the use of payment services.

Conclusion: The controls carried out by Nextimmo are essential to ensure that its operations are not used for illegal purposes. With constant vigilance and appropriate control measures, Nextimmo ensures compliance with the strictest regulations.