Services
Anti‑Financial Crime (AFC) support for Luxembourg regulated entities
Our services are designed in line with Luxembourg regulatory expectations, CSSF/AED circulars and applicable EU AML/CFT/CPF requirements. We support entities across the full compliance lifecycle – from governance and control functions to operational compliance and regulatory inspections.
Control Functions & Senior Mandates
Responsable du Contrôle (RC)
RC function aligned with Luxembourg regulatory requirements
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
Governance, Strategy & Framework
Anti-Financial Crime Consulting
Strategic AFC guidance aligned with CSSF/AED expectations
Financial Crime Framework
Structuring robust, CSSF/AED‑ready frameworks
AML/CFT/CPF Policies & Procedures
Clear and compliant documentation
Risk Assessment & Regulatory Readiness
AML/CFT/CPF Risk Assessment
Risk‑based analysis tailored to your business
AML/CFT/CPF Audit Preparation
Ready for internal and external audits
AML/CFT/CPF Inspections Preparation
Structured support for CSSF/AED reviews
Operational Compliance & Controls
AML/CFT/CPF Compliance
Day‑to‑day compliance advisory
KYC & CDD Services
Risk‑based onboarding and reviews
Transaction Monitoring
Effective monitoring and control design
Sanctions Compliance
Restrictive measures (sanctions) governance and screening
Ongoing Support & Outsourcing
AML/CFT/CPF Officer Support
Practical support for key control functions
Outsourced AML/CFT/CPF Activities
Flexible and compliant outsourcing
Sector‑Specific Expertise
AML/CFT/CPF for Investment Funds, ManCos and AIFMs
Fund‑specific compliance solutions
AML/CFT/CPF for Banks
Banking supervision‑focused support
AML/CFT/CPF for PSF & FinTech
Scalable solutions for regulated innovators
Bastian Schwind‑Wagner — Short profile
Bastian Schwind-Wagner is an experienced anti-financial crime (AFC) professional specialising in the Luxembourg market. He combines in-depth regulatory knowledge with practical implementation skills to deliver inspection-ready solutions.
Core competencies include:
- strategic design and implementation of AFC frameworks (governance, role allocation)
- alignment with CSSF/AED expectations and EU AML/CFT/CPF requirements (regulatory readiness, inspections)
- drafting and revising policies & procedures
- conducting and documenting risk assessments that link risks to controls
- 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 (EU/UN/OFAC relevance)
- AML internal audit preparation and independent reviews; support with CSSF/AED inspections
- operational and interim leadership: (interim) Conducting Officer — taking regulatory responsibility and managing remediation delivery
- board and governance support: Independent Non‑Executive Director (iNED) with AFC focus to strengthen oversight and documented challenge
- Responsable du Contrôle (RC): establish, strengthen or temporarily fill the RC function for independent, risk‑based control testing and board‑level reporting
-
outsourced activities: design, governance and oversight of outsourced AFC/AML/sanctions services
- Working style: pragmatic, inspection‑ready, focused on clear documentation, management information and sustainable implementation tailored to Luxembourg market specifics.
I look forward to working with you!
Kind regards,
