MoF, AED ¦ 2025 Activity Report ¦ Summary Financial Crime

Luxembourg’s 2025 Financial Crime Effort – Strengthening AML/CFT Frameworks and Supervisory Action

In 2025 Luxembourg’s financial crime division continued its dual approach of strategic preparation and operational enforcement to meet the recommendations issued by the Financial Action Task Force (FATF) and to implement the new AML6 package. At the regulatory level, preparatory work focused on three core instruments of the AML6 package: Regulation (EU) 2024/1620 establishing the EU anti‑money laundering authority, Directive (EU) 2024/1640 setting national mechanisms to prevent misuse of the financial system, and Regulation (EU) 2024/1624 addressing prevention of AML/CFT risks. Those developments have driven policy design, cross‑agency engagement and sectoral impact assessments within the Administration for the year.

Mandate and mission of the Financial Crime Service

The Financial Crime Division’s mission centers on prevention of money laundering and terrorist financing for entities under its AML/CFT supervision. Prevention work extends beyond issuing guidance documents to include active participation in sector conferences, desk‑based reviews and on‑site inspections. The Division also manages cooperation between the administration and judicial authorities for AML/CFT matters as well as criminal tax offenses. For 2025 the Division operated with a staff of 17 people and maintained a continuous outreach role to both the regulated sectors and internal stakeholders.

Key preventive and international measures

During 2025 the Division contributed to a national risk assessment (NRA) dedicated to terrorist financing and provided expert participation to AMLA expert groups and national working groups convened by the Ministry of Finance, aiming to implement AML6 provisions and evaluate their consequences for supervised sectors. The Division also manages access and declarations to the register of trusts and fiducies created under the July 10, 2020 law, enabling authorities to obtain beneficial ownership information for trusts. Cyclical processing of AML questionnaires and related injunctions supported compliance assessment across sectors, while regular updates to international financial sanctions lists and publication of guidance and technical sheets on the AED’s indirect tax portal strengthened prevention and awareness. At the time of reporting, the portal held 110 publications related to AML/CFT prevention and awareness.

Supervision, outreach and sanctions activity

The Division sustained communication and engagement with the financial sector, notably by participating in conferences addressing non‑prudentially supervised financial vehicles overseen by the Commission de Surveillance du Secteur Financier (CSSF) and by intensifying dialogue with sector professional associations. Enforcement action following desk and on‑site controls – resulting in administrative measures and sanctions – generated five amicable appeals and four contested appeals by affected professionals. The Division organized internal AML/CFT training for AED trainees and ensured ongoing operational readiness to apply the updated sanctions and registry obligations.

Bastian Schwind-Wagner _Follow

"The Financial Crime Division has shown measurable progress in aligning supervision and enforcement with the new AML6 framework while maintaining targeted oversight of high‑risk sectors such as real estate. Continued data collection, cross‑agency cooperation and a mix of desk and on‑site controls indicate a calibrated approach that balances prevention, detection and proportionate sanctions.

Regulated entities should prioritize updating customer due diligence, beneficial ownership and sanctions screening processes to meet evolving expectations. Prompt cooperation with supervisory requests and thorough documentation will reduce enforcement risk as authorities intensify sectoral scrutiny and implement AML6 provisions."

Targeted questionnaire campaign and sectoral findings – real estate

A targeted 2025 campaign focused on the real estate sector selected the 200 agents and developers with the highest turnover. Agencies were required to provide information on all counterparties with whom they maintained business relationships in 2021–2023 for purchases, sales or rentals with monthly rent at least equal to €10,000. Requested data included corporate names and trade register numbers for legal entities, and for natural persons: name, date of birth, residence and birth country, beneficial owner identification, PEP status and presence of international financial sanctions measures.

The campaign achieved high cooperation: 196 out of 200 professionals submitted the questionnaire within deadlines or after injunctions. Authorities issued 112 injunctions to non‑responders, with the administrative measure proving effective as 108 of those later complied. The questionnaires yielded an inventory of 6,588 real estate properties and 21,429 counterparties, including 14,297 natural persons (67%) and 7,002 legal entities (33%). These data supported evaluation of compliance with enhanced due diligence (EDD) obligations, identification of PEPs and higher‑risk foreign counterparties, and assessment of the effectiveness of sanctions screening and implementation.

On‑site controls and sector coverage

In 2025 the Division carried out 88 on‑site inspections across multiple sectors: two controls of accounting professionals, 37 of business centres (PSSF), one of precious metals, jewelers, watches, and old-gold operators, seven inspections of entities outside supervisory scope, 16 controls of real estate agents and 25 controls of real estate developers. This mix shows a clear supervisory focus on the non‑financial sector‑linked vulnerabilities and on intermediaries commonly involved in real estate and business centres.

Administrative measures and sanctions imposed

The Division issued four injunctions and imposed 27 fines over the year, alongside seven reprimands and ten warnings. Those measures reflect an enforcement posture that balances administrative action with proportionality while preserving the ability to escalate where systemic weaknesses or repeated non‑compliance persist.

Cooperation, working groups and judicial coordination

Following the FATF evaluation recommendations, the Committee for AML/CFT prevention continued to convene working groups through 2025. These forums provided common platforms for supervisory authorities to discuss remediation steps, develop practical tools and prepare future contributions. As an active member of these groups, the AED participated in developing operational solutions across awareness, controls, sanction implementation and risk‑based approaches. The Financial Crime Division also maintained statutory cooperation with judicial authorities under Luxembourg’s fiscal cooperation and AML laws, ensuring information sharing and joint action where investigations and prosecutions require coordination.

Implications and practical takeaways for practitioners

Luxembourg’s 2025 activity report demonstrates several clear trends relevant to compliance officers and advisers.

1. The practical implementation of AML6 is driving both regulatory change and intensified interagency coordination – firms should expect evolving obligations and prepare to update procedures, customer due diligence (CDD) and sanctions screening accordingly.
2. High compliance rates in the real estate questionnaire campaign show that targeted data collection, backed by administrative injunctions, is an effective supervisory tool; real estate intermediaries remain a priority for authorities.
3. The inventory of counterparties derived from questionnaires underscores the importance of rigorous beneficial ownership identification and PEP screening, particularly where high‑value transactions are involved.
4. The Division’s mix of desk reviews and on‑site inspections, combined with a non‑negligible sanction record, signals that supervisory tolerance for incomplete controls or weak implementation is limited.

Conclusion

The Financial Crime Division’s 2025 work program reflects a programmatic push to align national supervision with EU AML/CFT reforms and FATF recommendations while preserving hands‑on enforcement and sectoral outreach. For regulated entities the message is clear – anticipate further regulatory refinement under AML6, maintain robust AML/CFT programs, document cooperation with supervisory data requests, and strengthen sanctions and beneficial ownership procedures to meet intensified supervisory expectations.

Dive deeper

• AED ¦ Rapport d’activité 2025 ¦ Link