28 November 2025
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.
Constructive and Timely Mutual Legal Assistance and Extradition
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.
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.
Addressing Legal and Practical Obstacles
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.1 Assessing Risks and applying a Risk-Based Approach
C – compliant
R.2 National Co-operation and Co-ordination
C – compliant
R.3 Money laundering offence
C – compliant
R.4 Confiscation and provisional measures
LC – largely compliant
R.5 Terrorist financing offence
C – compliant
R.6 Targeted financial sanctions related to terrorism and terrorist financing
LC – largely compliant
R.7 Targeted financial sanctions related to proliferation
LC – largely compliant
R.8 Non-profit organisations
PC – partially compliant
R.9 Financial institution secrecy laws
C – compliant
R.10 Customer due diligence
C – compliant
R.11 Record-keeping
C – compliant
R.12 Politically exposed persons
C – compliant
R.13 Correspondent banking
C – compliant
R.14 Money or value transfer services (MVTS)
C – compliant
R.15 New technologies
LC – largely compliant
R.16 Payment transparency
C – compliant
R.17 Reliance on third parties
C – compliant
R.19 Higher-risk countries
C – compliant
R.20 Reporting of suspicious transactions
C – compliant
R.21 Tipping-off and confidentiality
C – compliant
R.22 DNFBPs: Customer due diligence
C – compliant
R.23 DNFBPs: Other measures
C – compliant
R.24 Transparency and beneficial ownership of legal persons
LC – largely compliant
R.27 Powers of supervisors
C – compliant
R.28 Regulation and supervision of DNFBPs
C – compliant
R.29 Financial intelligence units
C – compliant
R.30 Responsibilities of law enforcement and investigative authorities
LC – largely 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.37 Mutual legal assistance
C – compliant
R.38 Mutual legal assistance: freezing and confiscation
C – compliant
R.39 Extradition
C – compliant
R.40 Other forms of international co-operation
LC – largely compliant