Anti-Financial Crime Consulting Luxembourg
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.
Overview
Luxembourg’s financial sector operates under strong supervisory expectations in relation to the prevention of money laundering, terrorist financing, sanctions breaches, and other forms of financial crime. Regulated entities are expected to maintain Anti-Financial Crime frameworks that are risk-based, well-governed, and effective in practice. Anti-Financial Crime consulting in Luxembourg is increasingly focused on substance. Supervisory attention extends beyond policies and procedures to governance, oversight, and the ability of senior management to demonstrate informed control over financial crime risks. This applies across banks, investment funds, management companies, alternative investment fund managers (AIFMs), PSFs, and FinTechs.
The Luxembourg regulatory and supervisory context
Entities regulated in Luxembourg are expected to align with EU Anti-Financial Crime requirements while addressing local supervisory priorities and market-specific risk factors.
Management bodies are expected to:
- understand the institution’s financial crime risk profile
- ensure that frameworks are proportionate to activities and complexity
- maintain clear allocation of responsibilities
- demonstrate effective oversight and challenge
- evidence ongoing monitoring and remediation
Anti-Financial Crime arrangements must be capable of withstanding supervisory reviews and on-site inspections.
Our Anti-Financial Crime consulting services in Luxembourg
We provide Anti-Financial Crime consulting to Luxembourg regulated entities across the full lifecycle of framework design, enhancement, and regulatory readiness. Our support is tailored to the specific regulatory, organisational, and operational context of each client.
Our consulting services include:
- Anti-Financial Crime framework design and enhancement
- AML and sanctions governance and oversight
- Financial crime risk assessments
- Review and strengthening of policies and procedures
- Oversight of delegated and outsourced functions
- Support for remediation and supervisory findings
- Preparation for regulatory interaction and inspections
Our approach combines regulatory understanding with practical implementation experience in the Luxembourg market.
Support for senior management and key function holders
Supervisory expectations in Luxembourg place increasing responsibility on boards, conducting officers, and key function holders. Anti-Financial Crime consulting therefore often focuses on enabling senior management to fulfil their oversight responsibilities.
We support decision makers by:
- clarifying roles and accountability
- strengthening reporting and escalation processes
- enhancing management information
- supporting informed decision making and challenge
Clear documentation and governance are central elements of this support.
Practical and proportionate implementation
Effective Anti-Financial Crime frameworks must be proportionate, operationally workable, and integrated into existing governance and control structures. Overly theoretical solutions rarely meet supervisory expectations.
Our consulting approach focuses on:
- practical implementation
- clear documentation and evidence
- alignment with business models and risk profiles
- sustainability over time
Inspection readiness and remediation
Regulatory inspections and thematic reviews increasingly assess how Anti-Financial Crime controls operate in practice. Entities must be able to demonstrate not only the existence of frameworks, but also their effectiveness and ongoing oversight. We support clients in preparing for inspections, addressing findings, and implementing sustainable remediation measures.
How this service fits within our broader offering
Anti Financial Crime consulting in Luxembourg often spans multiple areas, including AML compliance, investor due diligence, transaction monitoring, sanctions compliance, and governance. Our consulting services are closely integrated with these specialised areas, which are covered on dedicated service pages within our Anti-Financial Crime offering.
Contact and next steps
If you are reviewing your Anti-Financial Crime framework, responding to supervisory feedback, or seeking targeted advisory support in Luxembourg, a structured and proportionate approach is essential.