Profiles
Bastian Schwind‑Wagner
Bastian Schwind-Wagner is an experienced anti-financial crime (AFC) professional specializing in the financial market, particularly in compliance for management companies and alternative investment fund managers. He combines in-depth knowledge with practical implementation skills to deliver review-ready solutions for financial crime prevention.
Core competencies include:
- board and governance support: Independent Non‑Executive Director (iNED) with AFC focus to strengthen oversight and documented challenge
- operational and interim leadership: (interim) Conducting Officer – taking regulatory responsibility and managing remediation delivery
- Responsable du Contrôle (RC): establish, strengthen or (temporarily) fill the RC function for independent, risk‑based control testing and board‑level reporting
- strategic design and implementation of AFC frameworks (governance, role allocation) aligned with CSSF and AED regulation, EU directives and regulations, and AMLA (earlier EBA, European Banking Authority) guidelines, as well as, statutory requirements
- structuring robust, CSSF/AED‑ready frameworks, vital for adherence to the latest circulars issued, focusing on the prevention of ML, TF and proliferation financing (PF), adhering to the regulatory landscape
- drafting and revising policies & procedures
- conducting and documenting risk evaluation that link risks to controls, fundamental for financial institutions in the context of AML, CTF and CPF
- KYC & CDD frameworks and investor due diligence with oversight of delegated functions
- transaction monitoring: scenario design, calibration, data quality and alert handling
- sanctions compliance: screening, escalation, and governance (UN/EU/national relevance) to combat ML, TF and proliferation financing (PF).
- internal audit preparation and independent analysis; support with CSSF/AED reviews.
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outsourced activities: design, governance and oversight of outsourced AFC, AML, trade financing and sanctions / embargo services
- Working style: pragmatic, inspection‑ready, focused on clear documentation, management information, and sustainable implementation tailored to market specifics and control structures.
I look forward to working with you!
Kind regards, in the spirit of enhancing Luxembourg's financial system

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✉E-mail us at e-mail@cetl.lu.
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☏You can also contact Bastian on +49 171 5356474. If he is unable to answer your call immediately, he will call you back.
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