FATF ¦ IO2 In­ter­na­tion­al Co­op­er­a­tion

FATF ¦ IO2 In­ter­na­tion­al Co­op­er­a­tion

Immediate Outcome 2: International Cooperation That Delivers Information, Intelligence and Action

Effective cross-border cooperation is essential for combating money laundering (ML), terrorist financing (TF) and related predicate crimes. Criminals exploit jurisdictional boundaries, moving people, funds and assets across countries to hide proceeds, launder value or find safe havens. A state that consistently provides and requests timely, high-quality international assistance reduces its attractiveness to offenders and strengthens global efforts to investigate, prosecute and recover illicit assets. Immediate Outcome 2 evaluates whether a country’s competent authorities — law enforcement, financial intelligence units (FIUs), prosecutors, supervisors, asset recovery bodies, customs and tax authorities — both deliver and seek the formal and informal cooperation needed to produce evidence, locate and extradite suspects, and identify, freeze, seize, confiscate and share criminal property or property of corresponding value.

Immediate Outcome 2
International co-operation delivers appropriate information, financial intelligence and evidence, and facilitates action against criminals and their property.

At the core of an effective system is the ability to respond constructively and promptly to mutual legal assistance (MLA) and extradition requests. This includes providing evidence, account and ownership information, witness testimony or other material necessary for foreign investigations and prosecutions related to ML, TF and associated predicate offences. The quality of assistance matters: requests should be answered with information that is complete, accurate and actionable, delivered in a timeframe aligned to the risks — particularly where asset dissipation is possible.

Equally important is the country’s own use of MLA and extradition to pursue foreign-located suspects or to secure evidence held abroad. Proactive and timely outgoing requests demonstrate a jurisdiction’s commitment to pursuing criminals and recovering assets. They also reflect an understanding of risk: authorities should prioritise assistance and requests that address the country’s high ML/TF risks and those that can produce concrete law enforcement or asset recovery outcomes.

The Role of Informal Cooperation and Networks

While treaties and formal channels are indispensable, informal cooperation — direct contact between counterpart authorities, the spontaneous sharing of financial intelligence, regional mechanisms and participation in multilateral networks (including Asset Recovery Inter-agency Networks) — is often the enabler of successful formal cooperation. Informal channels can accelerate evidence-sharing, clarify evidentiary and procedural requirements, and resolve issues of poor-quality requests or jurisdictional conflict before formal processes begin. Effective systems leverage these informal mechanisms to support MLA and extradition, improving timeliness and impact without undermining necessary safeguards.

Information and Assistance That Support Asset Recovery

Immediate Outcome 2 places particular emphasis on asset recovery: identifying, freezing, seizing, confiscating, repatriating and sharing proceeds and property of corresponding value. Competent authorities must be able to obtain and provide a wide array of information — financial records, beneficial ownership details, supervisory and tax information, real estate and vehicle registers, and financial intelligence. The ability to enforce foreign freezing, seizing and confiscation orders, including non‑conviction based orders where applicable, and to manage and repatriate recovered assets in accordance with law, is crucial to denying criminals the economic fruits of their crimes.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"Effective international cooperation is vital to disrupt cross-border money laundering and terrorist financing by ensuring timely exchange of evidence, extradition where appropriate, and enforcement of asset recovery measures. When formal mechanisms are supported by informal channels, clear safeguards, and adequate resourcing, authorities can better prevent asset dissipation and secure convictions.

Countries should align cooperation priorities with national ML/TF risk profiles and remove unnecessary legal or procedural barriers that impede assistance. Consistent, high-quality responses and active participation in multilateral networks build trust with partners and increase the likelihood of successful prosecutions and repatriation of illicit assets."

Quality, Prioritisation and Risk Alignment

Assessing effectiveness requires balancing quantity of cooperation with quality and impact in light of the country’s risk profile. Authorities should demonstrate that their cooperation efforts are aligned with national risk priorities: the nature, timeliness and prioritisation of requests and responses should reflect the scale and types of ML/TF threats the country faces. Case studies, statistics on requests made and received, and feedback from foreign counterparts help form a rounded view of how responsive and useful the jurisdiction is to international partners.

Operational Safeguards and Case Management

Robust operational measures underpin trustworthy cooperation. Safeguards should ensure confidentiality, proper use of exchanged information, and protection of investigative integrity. Case management systems and clear mechanisms for receiving, assessing, prioritising and responding to requests are essential. These tools help authorities provide accurate, sufficiently detailed requests to enable proper assessment by requested jurisdictions, and to deliver timely feedback and follow-up. Clear contact points and guidance on evidentiary and procedural expectations further reduce friction and delays.

Legal or procedural obstacles can hinder cooperation: overly narrow dual criminality interpretations, unduly restrictive grounds for refusal, or gaps in domestic frameworks for designated offences (as covered under other FATF recommendations) may block assistance. Effective systems minimize such barriers and, where extradition is not legally possible, ensure prosecution of nationals domestically without undue delay. Countries should also have arrangements to withhold consent or suspend transactions suspected of ML/TF at foreign request, and processes for recognizing and enforcing foreign asset recovery orders when appropriate.

Measuring Success: Evidence and Outcomes

Evidence of an effective international cooperation regime is multidimensional. Relevant indicators include statistics on requests (made, received, granted, refused), timeliness and prioritisation, instances of spontaneous exchange, and concrete case outcomes — extraditions, prosecutions, convictions, and recovered or repatriated assets. Demonstrable contributions to foreign investigations, such as joint investigations, assistance that enabled successful prosecutions abroad, or enforcement of foreign freezing and confiscation orders, are strong markers of effectiveness. Feedback from international partners and participation in multilateral fora further corroborate a country’s constructive role.

Resourcing and Institutional Capacity

Finally, adequate resourcing matters: countries must ensure sufficient personnel, technical systems and legal frameworks are in place to manage incoming and outgoing requests, preserve assets at risk of dissipation, and coordinate across competent authorities. Where resources are scaled to the country’s risk, the system is more likely to respond promptly and effectively, generating trust among international partners and improving overall global capacity to disrupt criminal networks.

Conclusion

Immediate Outcome 2 assesses whether international cooperation delivers the right information, intelligence and evidence, and whether it facilitates timely action against criminals and their property. Success depends on a balanced combination of high-quality MLA and extradition responses, proactive use of formal requests, effective informal cooperation and networks, operational safeguards and case management, legal frameworks that do not unduly block assistance, and adequate resourcing. When these elements work together and are aligned with the country’s risk profile, the jurisdiction becomes less attractive to offenders and more effective in depriving criminals — including terrorists — of their ill-gotten gains.


FATF Ratings Overview
Luxembourg ¦ FATF Effectiveness & Technical Compliance Ratings

Anti-money laundering and counter-terrorist financing measures

Luxembourg Mutual Evaluation Report, September 2023

This assessment was adopted by the FATF at its June 2023 Plenary meeting and summarises the anti-money laundering and counter-terrorist financing (AML/CFT) measures in place in Luxembourg as at the date of the on-site visit: 2-18 November 2022.

Table 1. Effectiveness Ratings

Note: Effectiveness ratings can be either a High- HE, Substantial- SE, Moderate- ME, or Low – LE, level of effectiveness.

IO1 Risk, policy and coordination

Money laundering and terrorist financing risks are identified, assessed and understood, policies are co-operatively developed and, where appropriate, actions co-ordinated domestically to combat money laundering and the financing of terrorism.

Substantial

IO2 International cooperation

International co-operation delivers appropriate information, financial intelligence and evidence, and facilitates action against criminals and their property.

Substantial

IO3 Supervision

Supervisors appropriately supervise, monitor and regulate financial institutions and VASPs for compliance with AML/CFT requirements, and financial institutions and VASPs adequately apply AML/CFT preventive measures, and report suspicious transactions. The actions taken by supervisors, financial institutions and VASPs are commensurate with the risks.

Moderate

IO4 Preventive measures

Supervisors appropriately supervise, monitor and regulate DNFBPs for compliance with AML/CFT requirements, and DNFBPs adequately apply AML/CFT preventive measures commensurate with the risks, and report suspicious transactions.

Moderate

IO5 Legal persons and arrangements

Legal persons and arrangements are prevented from misuse for money laundering or terrorist financing, and information on their beneficial ownership is available to competent authorities without impediments.

Substantial

IO6 Financial intelligence

Financial intelligence and all other relevant information are appropriately used by competent authorities for money laundering and terrorist financing investigations.

Substantial

IO7 ML investigation & prosecution

Money laundering offences and activities are investigated, and offenders are prosecuted and subject to effective, proportionate and dissuasive sanctions.

Moderate

IO8 Confiscation

Asset recovery processes lead to confiscation and permanent deprivation of criminal property and property of corresponding value.

Moderate

IO9 TF investigation & prosecution

Terrorist financing offences and activities are investigated and persons who finance terrorism are prosecuted and subject to effective, proportionate and dissuasive sanctions.

Substantial

IO10 TF preventive measures & financial sanctions

Terrorists, terrorist organisations and terrorist financiers are prevented from raising, moving and using funds.

Moderate

IO11 PF financial sanctions

Persons and entities involved in the proliferation of weapons of mass destruction are prevented from raising, moving and using funds, consistent with the relevant UNSCRs.

Moderate

Table 2. Technical Compliance Ratings

Note: Technical compliance ratings can be either a C – compliant, LC – largely compliant, PC – partially compliant or NC – non compliant.

R.8 Non-profit organisations

PC – partially compliant

R.10 Customer due diligence

C – compliant

R.11 Record-keeping

C – compliant

R.13 Correspondent banking

C – compliant

R.15 New technologies

LC – largely compliant

R.16 Payment transparency

C – compliant

R.19 Higher-risk countries

C – compliant

R.23 DNFBPs: Other measures

C – compliant

R.27 Powers of supervisors

C – compliant

R.32 Cash Couriers

LC – largely compliant

R.33 Statistics

LC – largely compliant

R.34 Guidance and feedback

C – compliant

R.35 Sanctions

LC – largely compliant

R.36 International instruments

LC – largely compliant

R.39 Extradition

C – compliant


The information in this article is of a general nature and is provided for informational purposes only. If you need legal advice for your individual situation, you should seek the advice of a qualified lawyer.
Did you find any mistakes? Would you like to provide feedback? If so, please contact us!
Dive deeper
  • FATF ¦ The FATF Recommendations ¦ Link
  • FATF ¦ Luxembourg’s measures to combat money laundering and terrorist financing ¦ Link
Bastian Schwind-Wagner
Bastian Schwind-Wagner Bastian is a recognized expert in anti-money laundering (AML), countering the financing of terrorism (CFT), compliance, data protection, risk management, and whistleblowing. He has worked for fund management companies for more than 24 years, where he has held senior positions in these areas.