FATF ¦ IO6 Fi­nan­cial In­tel­li­gence

FATF ¦ IO6 Fi­nan­cial In­tel­li­gence

Immediate Outcome 6: From Reports to Results

Immediate Outcome 6 evaluates

  • whether a jurisdiction’s financial intelligence unit (FIU) and other competent authorities have timely access to a broad range of relevant, accurate and up‑to‑date information;
  • whether the FIU produces analytical financial intelligence that meets operational needs; and
  • whether that intelligence is effectively shared and used to investigate money laundering (ML), associated predicate offences and terrorist financing (TF).

This outcome sits at the core of an effective anti‑money laundering and counter‑financing of terrorism (AML/CFT) system because high‑quality financial intelligence and its operational use are what turn raw reports and records into investigations, asset tracing and prosecutions.

Immediate Outcome 6
Financial intelligence and all other relevant information are appropriately used by competent authorities for money laundering and terrorist financing investigations.
Access to information: breadth, timeliness and quality

An effective system ensures the FIU and other competent authorities can access a wide variety of sources: suspicious transaction reports (STRs), cash and currency/bearer negotiable instrument reports, wire‑transfer records, supervisory and regulatory data, law enforcement intelligence, company and asset registries, tax information, social‑benefit and customs data, and where relevant, CDD and transaction records from financial institutions, DNFBPs and VASPs. The information must be relevant, accurate and current, and accessible in a timely way. Assessors should judge whether national legislation and operational arrangements actually enable this access in practice, and whether any legal or practical impediments (for example, overly restrictive secrecy rules or technical bottlenecks) prevent the FIU or investigators from obtaining information needed for analysis and follow‑up.

Production of financial intelligence and analytical rigor

The FIU should have sufficient resources, expertise and analytical tools to turn reports and data into actionable financial intelligence. This means using data‑mining, link analysis, case development techniques and subject‑matter expertise to add value to STRs and other inputs. Quality control and rigorous analytical methodologies are essential so outputs are reliable and defensible in operational contexts. Where other competent authorities also perform financial intelligence analysis, they must be resourced and capable of leveraging both their own data and FIU products. Assessors must consider the alignment of analytical priorities with ML/TF risk assessments so that FIU outputs focus on the country’s principal threats and vulnerabilities.

Cooperation, secure exchange and protection of confidentiality

Regular, secure and reciprocal information exchange between the FIU and law enforcement, prosecutors, supervisory authorities and other competent bodies is a core element. Mechanisms such as joint task forces, secondments, shared databases and formal exchange protocols promote integration of financial intelligence into investigations. Maintaining confidentiality and robust information‑security measures is equally important: authorities must protect the sensitive information they handle and ensure dissemination rules are respected so that trust is preserved and international cooperation remains viable.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"Financial intelligence must be timely, relevant and actionable to support investigations into money laundering and terrorist financing. When FIUs and competent authorities have fast access to a broad set of accurate data and the analytical capacity to convert it into operational leads, investigations proceed more quickly and asset tracing becomes more effective.

Sustained cooperation and secure information‑sharing are essential; without them even high‑quality analysis can fail to produce results. Strengthening legal frameworks, resourcing FIUs and improving reporting quality through feedback and typologies will materially increase the impact of financial intelligence."

Use of financial intelligence in investigations and asset tracing

The ultimate measure of effectiveness is whether financial intelligence and other information are used to develop evidence, identify and trace criminal proceeds and instrumentalities, and advance investigations and prosecutions of ML, associated predicate offences and TF. Assessors should look for concrete examples where FIU products or other intelligence led to investigative leads, arrests, asset freezes/seizures, successful prosecutions or confiscation of proceeds. The routine incorporation of FIU feedback, operational experience and typologies into reporting guidance and analytical practices demonstrates a learning system that improves over time.

Key indicators assessors consider

To determine whether this Immediate Outcome is achieved, assessors review a range of indicators:

  • the number and quality of STRs analysed; the FIU’s receipt and analysis of currency and bearer instrument reports;
  • statistics on dissemination of FIU products and their use by law enforcement and prosecutors;
  • examples of cases where financial intelligence supported investigations and asset recovery; and
  • evidence of secure, regular information exchange with domestic and foreign partners.

They also examine capacity factors — whether competent authorities have the staffing, training and IT tools (including for data‑mining and confidentiality protections) to carry out analysis and operational follow‑up.

Common weaknesses and impediments

Shortfalls that commonly undermine this outcome include restricted or delayed access to key information sources, under‑resourced FIUs and investigative units, weak analytical frameworks, poor feedback loops and lack of secure information‑sharing mechanisms. Legal constraints preventing FIUs from accessing required data or from sharing FIU products with investigators can also critically limit impact. Gaps in reporting quality — incomplete or low‑value STRs — reduce the analytic yield unless the FIU actively engages in outreach to improve reporting standards.

What improvement looks like

An effective jurisdiction demonstrates that the FIU is the national focal point for STRs and that it regularly produces high‑quality analytical products, aligned with national ML/TF risks. There is demonstrable, secure and timely cooperation between the FIU, law enforcement, prosecutors, supervisors and other authorities, with concrete case examples where financial intelligence has directly supported investigations, tracing and recovery of assets and successful prosecutions. Feedback mechanisms and typologies inform reporting entities and improve STR quality. Adequate resources, technical tools and legal frameworks protect operational independence and confidentiality while enabling effective domestic and international exchange.

Conclusion

Immediate Outcome 6 measures whether financial intelligence is not merely collected but transformed into operational value. The effectiveness of an AML/CFT system depends on timely access to diverse information sources, rigorous FIU analysis, secure and functioning cooperation mechanisms, and demonstrable use of that intelligence to investigate ML/TF, identify and trace proceeds, and support prosecutions and asset recovery. Assessors focus on real‑world results and capacities, ensuring that country‑specific ML/TF risks drive priorities and that legal, operational and technical arrangements enable, rather than hinder, the production and operational use of financial intelligence.


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.
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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.