MUFG Lux Management Company S.A. uses Cascade to strengthen AML/KYC and free time for higher-value risk work

Interview with Pieter Siebens, Conducting Officer, Head of Compliance/RC, MUFG Lux Management Company S.A.

Pieter Siebens brings a practitioner’s clarity to AML/KYC grounded in day-to-day accountability and shaped by the broader perspective he also shares as a guest lecturer. He frames the goal of modern compliance in a way that is both simple and demanding:

“The ideal is when the cake is being prepared by the technology, and the icing or the cherry on top is being put by the humans… we will not fight money laundering by ticking boxes… but by allocating time to investigate the outliers, the particular cases, the interpretation of what is discovered.”

This use case shows what that vision looks like in practice: using Cascade to reduce time spent on administrative effort and evidence gathering, so compliance professionals can focus more on judgement, contextual assessment, and investigation in support of AML/CFT objectives.

The context: rising expectations, uneven interpretation, and the operational cost of ambiguity

In Luxembourg, Pieter has seen AML/CFT and KYC priorities increasingly shaped by:

• CSSF requirements regarding assets screening,
• a stronger focus on UBO identification, and
• AML/KYC applied to non-core service providers.

At the same time, he highlights where the risk-based approach becomes hardest to execute consistently: ongoing monitoring, particularly on the assets side, where uncertainty persists around “how far to go” and “what to document.” He notes that differences in approach across jurisdictions make it harder to align counterparties (such as portfolio managers) with Luxembourg requirements.

The practical implication, in his view, is that compliance teams are often forced to spend time not only on execution, but on navigating differing interpretations and building defensible evidence of consistency.

Why Cascade: one structured system that makes AML/KYC work visible, consistent, and audit-ready

Pieter’s assessment of Cascade is direct. Since adoption, what improved most is “all of the words you mention”:

• Speed: “no looking around in various folders and excels”
• Consistency: “1 database, source, no various docs and excels spread over different locations”
• Visibility: “topics are structured in a clear way, making our activities and controls very visible”
• Audit trail: “everything is clearly documented in Cascade, with history tracks for most of the items”
• Data quality: “1 source, 1 database”

He adds a point that matters when platforms have to work beyond the compliance team: a “user friendly interface.” Pieter notes that internal training for non-Compliance staff typically takes about one hour, and that this is sufficient for people to use the platform.

Before and after Cascade: annual internal audit of AML activities

To make the impact tangible, Pieter points to a recurring, high-stakes moment for any compliance function: the annual internal audit on AML activities.

Before Cascade

• Documents were “spread over various folders and servers”
• Compliance had to copy them to a location accessible by Internal Audit
• The process was “very time consuming” for both teams, with follow-up questions when answers were not immediately visible
• “Not all our controls were visible to Internal Audit”: demonstrating controls required walking auditors through processes and documentation

With Cascade

• Internal Audit received Cascade training and view access
• Since 2 years, Internal Audit performs its AML audit by consulting Cascade directly
• Compliance receives only “a few minor questions for clarification”
• “A lot of time is saved” on both sides, making the process “much more efficient”
• Internal Audit can “focus on what matters, not just on gathering the data”

The outcome Pieter is advocating for

Pieter’s “cake and cherry” analogy is ultimately a call for focus: technology should take care of the repeatable foundations, i.e. documentation, workflow, visibility, audit trail, so that compliance professionals can spend their limited time where it has the most value: outliers, contextual risk assessment, and interpretation.

About MUFG

Mitsubishi UFJ Financial Group, Inc. (MUFG) is one of the world’s leading financial
groups. Headquartered in Tokyo and with over 360 years of history, MUFG has a global
network with approximately 2,000 locations in more than 40 countries. The Group has
about 150,000 employees and offers services including commercial banking, trust
banking, securities, credit cards, consumer finance, asset management