Anti-Financial Crime (AFC) Services
Practical Anti‑Financial Crime support for Luxembourg regulated entities, aligned with CSSF regulation, AED expectations, EU AMLD, AMLA/EBA and FATF standards.
The following information is provided for general informational purposes and does not form part of our editorial content. It relates to our professional services in Financial Crime.
The services described are provided by
concilio et labore GmbH,
which was founded by Bastian Schwind-Wagner. Bastian is a Certified Anti-Financial Crime Professional (CAFCP), a qualification validated by TU Dublin.
Anti‑Financial Crime (AFC) Support for Luxembourg Regulated Entities
Practical, regulator-ready anti financial crime support tailored to regulated entities – ensuring compliance with CSSF/AED guidance, EU AML specific regulatory requirements, AMLA/EBA and FATF standards, as well as, local reporting obligations.
Why Choose Our AFC Support
- Deep local expertise: specialists with direct experience working with funds (AIFs, RAIFs, UCITS), fund managers (AIFMs, ManCos), banks, payment institutions, trustees, investment firms and payment service providers.
- Alignment: solutions designed for CSSF/AED expectations, AMLD transposition and FATF recommendations.
- End-to-end services: from risk evaluation to monitoring, investigations, SAR filing, and improvement for AML processes, we ensure adherence to the regulatory landscape.
- Scalable delivery: anti-financial crime solutions for financial institutions must be ensured and aligning with supervisory priorities; on-site, hybrid or fully managed AFC operations for single entities or groups.
Core Anti‑Financial Crime Services for Luxembourg Entities
Control Functions & Senior Mandates
Responsable du Contrôle (RC)
RC function aligned with national requirements for anti-money laundering (AML), counter terrorist financing (CTF), counter proliferation financing (CPF)
Interim Management – Conducting Officer
Senior management support during transition or regulatory pressure
Independent Non-Executive Director (iNED)
Independent AFC/AML/CFT/CPF and compliance oversight to address financial crime risks in financial institutions must be prioritized.
Governance, Strategy & Framework
Anti-Financial Crime Consulting and Advisory
Strategic AFC guidance aligned with CSSF/AED expectations, inspections and thematic reviews
Anti-Financial Crime Framework
Structuring robust, CSSF/AED‑ready frameworks is vital for adherence to the latest circulars and guidelines issued by regulators.
AML/CFT/CPF Policies & Procedures
Clear and compliant documentation that meets international standards
Risk Assessment & Regulatory Readiness
Risk Assessment
Risk‑based analysis tailored to your business
Audit Preparation
Ready for internal and external reviews: Preparation is necessary to ensure alignment with the latest guidelines and expectations.
Inspections Preparation
Structured support for CSSF/AED reviews
Remediation (Post‑Inspection)
Well‑structured enhancement after an on-site visit or thematic review
Operational Compliance & Controls
AML/CFT/CPF Compliance
Day‑to‑day compliance advisory focused on anti-money laundering (AML), counter terrorist financing (CTF) and counter proliferation financing (CPF)
KYC & CDD Services
Risk‑based onboarding and reviews, including identification and verification processes
Transaction Monitoring
Effective monitoring and control design is essential for meeting the ongoing due diligence (ODD) requirements set by regulators.
Sanctions Compliance
Restrictive measures (sanctions) governance and screening
Ongoing Support & Outsourcing
AML/CFT/CPF Officer Support
Practical support for key control functions to manage and mitigate risks
Outsourced AML/CFT/CPF Compliance Activities
Flexible and compliant outsourcing solutions are essential for firms and managers aiming to meet national and international standards, including anti-financial crime measures.
Sector‑Specific Expertise for regulated entities in the financial sector
AML/CFT/CPF for Investment Funds, ManCos and AIFMs
Fund‑specific compliance solutions for AML, CFT and CPF are crucial for investment fund managers.
AML/CFT/CPF for Banks
Emphasizing the need for robust control structures and adherence to statutory regulations: banking supervision‑focused support for credit institutions
AML/CFT/CPF for Specialised PFS & FinTech
Scalable solutions for regulated innovators
Our Approach for Luxembourg Regulated Entities
- Assess: A quick baseline review against supervisory expectations and EU AML requirements is crucial for effective prevention of money laundering and terrorist financing, as well as, fraud prevention.
- Prioritise: Prioritise actions to address ML and TF to align rectification to risk and deadlines.
- Design: Design a risk-based approach to mitigate risks while adhering to guidelines and expectations. Build pragmatic policies, procedures, controls, and governance fit for market realities, in line with the customer due diligence (CDD) and enhanced due diligence (EDD) expectations.
- Deliver: Deploy people, processes and solutions for AML and CTF, as well as, CPF – Supervised by experienced AFC leads, in accordance with industry best practice.
- Assure: Continuous monitoring, independent testing, and regulator-ready reporting are essential for the prevention of financial crime.
Benefits You’ll See
- Reduced regulatory risk and improved readiness for CSSF (Commission de Surveillance du Secteur Financier) and AED (Administration de l’Enregistrement, des Domaines et de la TVA) on-site inspections.
- Reduced operational costs by optimised monitoring and alert handling in line with regulatory requirements.
- Stronger evidence of an effective AML/CFT/CPF environment for boards and supervisors.
- Faster, more defensible decision-making on high-risk clients and transactions related to financial crime risks.
- Best practices to strengthen governance and reduce the risk of reputational damage
Frequently Asked Questions (FAQ)
What does anti-financial crime (AFC) cover for financial entities?
Anti financial crime covers AML/CFT, CPF, restrictive measures, bribery and corruption screening, fraud detection, KYC/CDD, and controls to prevent misuse of financial services in accordance with the AMLA/EBA and national guidelines and expectations. For regulated entities it must align, inter alia, with CSSF/AED guidance, EU AML requirements and FATF recommendations.
Do you provide on-site support for CSSF and AED reviews?
Yes. We provide on-site readiness assessments, regulator liaison assistance and update support to ensure findings are addressed timely.
How do you ensure technology choices meet regulatory expectations?
We evaluate solutions against data quality, explainability, audit trails and governance requirements; we also document model risk management for any AI/ML used in monitoring.
Can you support multi-jurisdictional groups with Luxembourg operations?
Yes. We coordinate centralized policies with local implementing procedures to meet group standards and specific national regulatory obligations.
Get Started with Anti Financial Crime (AFC) Support for Luxembourg Regulated Entities
Contact us to arrange a free initial consultation and gap assessment to help you comply with regulatory expectations and guidelines. We will deliver a pragmatic roadmap to meet CSSF, AED, and EU requirements, ensuring abidance by the laws while reducing operational burden in the financial sector through a proportionate approach.
✒Send us a message and we’ll get back to you.
✉E-mail us at e-mail@cetl.lu.
Rest assured, your query is important to us and we will respond shortly.
☏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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