ACAMS Luxembourg Chapter June 2026 Event: Enforcement of Sanctions as the Third Pillar of AML: A Silent Reform

Ani Ghambaryan is currently Compliance Manager at Finance in Motion GmbH, a leading impact asset manager with many years of experience in impact investing, with emphasis on generating positive change in emerging markets including countries of the ACAMS Eurasia Chapter, through implementation of impact driven investment vehicles and investment solutions that contribute to the United Nations’ Sustainable Development Goals (SDGs).

Previously she held senior managerial positions such as Director of Risk Management, internal control and compliance department and a Member of the Management Board at ArmbusinessBank CJSC and an Executive Board Member in ProCredit Bank Armenia, part of the international banking group ProCredit. She was responsible for the implementation and development of the AML/ compliance, internal control and risk management, Information security functions for both banks.

Ani is also experienced and skilled in advisory roles. She has been a successful advisor to the project of implementation and improvement of AML and Compliance functions for a financial institution in Tajikistan and other non-EU countries for a considerable period.

Simultaneously Ani is a lead trainer for numerous international and local certification programs. She has been providing training to the banking sector participants since 2015, particularly on the improvement of AML and compliance, risk management topics of CMI (Chartered Management Institute) certification, FRR (GARP certification).

She holds a master’s degree in finance and banking, and bachelor’s degree in economics from the Yerevan State University, is an active ACAMS member and holds both the CAMS and CAMS-RM Certifications.

Stanislaw Tosza is a Full Professor in Compliance and Law Enforcement. He is also the co-Director of the Bachelor in Law programme. He teaches and researches comparative and European criminal law, white-collar crime, compliance law and cyberlaw.

Before joining the University of Luxembourg, Stanislaw was assistant professor at the Willem Pompe Institute of Criminal Law and Criminology at Utrecht University. As visiting researcher he spent also time at Georgetown University Law Center, D.C. (2019), Berkman Klein Center at Harvard University (2017) and Max Planck Institute for Foreign and International Criminal Law in Freiburg i.B. (2008-2010). He defended cum laude his PhD thesis on criminal liability of managers for excessive risk-taking at Utrecht University and at the University of Luxembourg in 2016.

He has extensive experience in research on EU criminal law and criminal investigation, which includes numerous articles and participation and leading projects in such areas as the rules of criminal procedure for the European Public Prosecutor’s Office, cooperation in criminal matters in the EU, gathering and use of electronic evidence for criminal investigations at EU and national level, the EU anti-money laundering reform, enforcement of international sanctions (restrictive measures), regulation of the metaverse and the role of private actors in enforcement. Stanislaw published four books: a monography “Criminal Liability of Managers in Europe. Punishing Excessive Risk White Collar Crime” (Hart 2018), and three collective volumes: “White collar crime. A Comparative Perspective” (Hart 2018), “Combatting illicit trade in tobacco products” (Springer 2022) and “The Cambridge Handbook of Digital Evidence in Criminal Investigations” (Cambridge University Press 2025).

Since 2019 he has been the Secretary General of the International Association of Penal Law (AIDP).

Sarah has over 15 years of experience from the financial industry and has specialized in Transfer Agency and Large Scale Project Management. She has extended experience in Regulatory Implementation and Change Management cross business lines and jurisdictions.

Prior to joining BDO in 2023, Sarah has worked for financial enterprises and banks in both Sweden and France. She has additional over 15 year’s experience from a major custodian bank in Luxembourg, where she has worked in the Transfer Agency department and with the daily fund cycles, as well as with large regulatory subjects (4AMLD, 5AMLD, MIFID, GDPR, DAC6) and later as a Compliance AML KYC expert leading projects on a global level.

Sarah holds a degree of international Economics and Business administration from the university of Växjo in Sweden. She additionally holds a CAMS certification from 2021.