11 February 2026
Barreau ¦ Rapport Annuel AML/CFT 2024-2025
Lawyers and AML/CFT in Luxembourg – Key Developments and Lessons from the 2024–2025 Annual Report
The Ordre des Avocats du Barreau de Luxembourg published its 2024–2025 AML/CFT annual report in February 2026, documenting legislative changes, supervisory activity, enforcement outcomes and capacity‑building measures affecting lawyers as a supervised profession. The period saw important legal amendments at national level and continuing preparatory work for major European reforms that will reshape anti‑money laundering architecture and obligations for non‑financial professionals.
At national level, several laws modified the AML/CFT framework: notably a December 2024 reform creating a Committee for prevention of money laundering and terrorist financing, and further statutes in early and late 2025 that updated registers, clarified information to be recorded at the Trade and Companies Register (RCS) and broadened the catalogue of predicate offences. These changes expand reporting lines and strengthen supervisory tools that impact lawyers’ duties. The Ordre welcomed the transposition work that extended lawyer access to the Register of Beneficial Owners (RBE), enabling checks not only on clients but also on counterparties relevant to transactions.
On the European front, practitioners should note the scheduled application of a new EU AML Regulation from 10 July 2027 and the need to transpose an updated anti‑money‑laundering directive by the same date. These instruments will introduce direct EU rules, create a European AML supervisory authority (AMLA) and require member states to set up public national supervisors to oversee any delegated supervision model for non‑financial professions. The Ordre is actively following and participating in the domestic implementation work via the national prevention committee.
Supervision, controls and enforcement outcomes
The Ordre’s supervisory activity blends on‑site inspections and mandatory online questionnaires, administered since 2023 through an AML platform that supports off‑site questionnaires, risk scoring and analytics. During the 2024–2025 judicial year, 20 on‑site AML/CFT controls were completed covering 301 lawyers (around 8.4% of the Bar), and three mandatory online campaigns were run: a sub‑sector questionnaire for lawyers acting as qualified directors for trust or company service providers (TCSPs), an infrastructure survey to map practice types and an annual general questionnaire for lawyers and law firms. The infrastructure mapping identified 713 active law firms and underpinned targeted annual risk assessments.
Overall, since the scheme began, 213 on‑site AML/CFT inspections have been carried out covering 2,225 lawyers – roughly 65% of members have faced at least one on‑site visit over nine years. The Ordre uses a risk‑based approach, relying on the questionnaire responses and a scoring engine to prioritise inspections and allocate supervisory resources.
Disciplinary activity and remedial measures
A total of 162 disciplinary procedures with an AML focus were opened in 2024–2025, a modest increase on the previous year. Procedures arose largely from failure to respond to mandatory questionnaires (153 cases) and from on‑site checks (9 cases). The Ordre pursued a mix of outcomes: many matters were closed after remediation, a small number were referred to the disciplinary council and several sanctions were imposed where non‑cooperation or persistent non‑compliance persisted. Notable measures included fines, temporary suspensions and publication of decisions. The report highlights that nearly all matters opened after on‑site inspections resulted in remediation measures and that a majority of questionnaire‑linked files were similarly remediated.
Reporting of suspicious activity and use of goAML
Reporting to the Financial Intelligence Unit (Cellule de Renseignement Financier – CRF) is via goAML, now the exclusive legal channel. The Ordre confirmed strong growth in goAML registration among lawyers and law firms: as of September 2025, 1,270 individuals were registered on goAML for 1,085 declaring entities. Between 15 September 2024 and 14 September 2025 lawyers filed 76 reports to the CRF. Most reports concerned suspicious activity, with a small number being information‑only returns. The Bâtonnier (the president of the bar association) continued to follow up on nearly all reports received by the Ordre, and only one report was not continued because it fell outside the AML remit.
The trend over recent years shows fluctuations in annual report counts but a steady and substantial increase in goAML registrations and overall reporting capacity. The CRF reports improved quality of submissions, suggesting better understanding of reporting thresholds and content among lawyers.
Key supervisory observations and areas for improvement
The Commission de Contrôle du Barreau de Luxembourg (CCBL) praised members’ overall commitment and cooperation but signalled recurrent weaknesses that supervisors will continue to monitor. Those include insufficient understanding of business relationships, weak critical analysis of collected client data leading to inconsistent risk ratings, inadequate in‑house AML training for responsible compliance staff and support personnel, shortcomings in firm‑level risk self‑assessment and gaps in procedures to address terrorism financing risks. The CCBL underlined the need for timely updating of internal AML policies to reflect fast‑moving legal changes.
Capacity building, tools and collaborative engagement
In response, the Ordre intensified training and digital tools. Eleven AML‑related training sessions were delivered in 2024–2025 covering basic principles, internal organisation, on‑site control process, targeted financial sanctions, beneficial‑owner identification, client risk analysis and initial customer due diligence. These sessions are available on the Bar’s online space and will be consolidated into a dedicated e‑learning platform planned for launch in the first quarter of 2026. The Ordre also invested in a platform for AML risk scoring and contracted a partnership to support public‑data screening in supervisory work.
The Ordre maintained active cooperation with the CSSF, the CRF, Ministry of Justice and Ministry of Finance. It participates in the national prevention committee and several working groups focused on non‑financial sectors. Internationally, Luxembourg’s Bar engaged with other European bars to exchange supervisory practices and demonstrated its AML risk model to peers.
What practitioners should take away
Lawyers operating in Luxembourg should consider the 2024–2025 report as both a progress report and a reminder of evolving expectations.
Practical takeaways include the need
- to maintain current, risk‑based client acceptance and monitoring systems;
- to ensure firm‑level AML policies and role descriptions are up to date;
- to deliver targeted AML training to compliance officers and support staff; and
- to document risk reasoning and due diligence in a way that supports the firm’s risk ratings and any subsequent supervisory review.
Access to the Register of Beneficial Owners for AML checks is now clearer for lawyers, and goAML registration and reporting remain central compliance duties.
The broader regulatory horizon will bring more stringent EU rules and a modified supervisory architecture. Firms should prepare now by strengthening internal risk assessment capabilities and improving documentation and reporting practices, so they can demonstrate robust compliance and cooperation if inspected.
Conclusion
The Ordre des Avocats du Barreau de Luxembourg’s annual AML/CFT report shows a maturing supervisory regime with widening use of digital tools, growing engagement from lawyers in suspicious‑activity reporting and a pragmatic enforcement approach focused on remediation. At the same time the report signals persistent operational gaps that firms must address to meet rising domestic and EU expectations. Lawyers should view the next two years as a transition period – an opportunity to upgrade internal controls and training so they remain compliant and resilient as Europe’s AML framework tightens.
Dive deeper
- Barreau de Luxembourg ¦ LBC/FT Généralités, Rapport annuel AML/CFT 2024-2025 ¦ Link
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