AML/CFT/CPF Compliance 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
Entities regulated in Luxembourg are required to maintain AML/CFT/CPF compliance frameworks that are risk-based, well-governed, and effective in practice. Supervisory expectations focus on the ability of institutions to demonstrate compliance not only through policies and procedures, but through operational controls, governance, and ongoing oversight. AML/CFT/CPF compliance in Luxembourg requires a structured approach that reflects the institution’s business model, risk profile, and regulatory perimeter. Management bodies are expected to understand AML/CFT/CPF risks, take ownership of compliance arrangements, and ensure that weaknesses are identified and addressed in a timely manner.
The Luxembourg AML/CFT/CPF regulatory environment
Luxembourg’s AML/CFT/CPF supervisory framework is aligned with EU legislation and places strong emphasis on substance and accountability.
Regulated entities are expected to:
- apply a documented risk-based approach
- maintain clear allocation of AML/CFT/CPF roles and responsibilities
- ensure effective governance and oversight
- implement adequate controls and monitoring
- evidence remediation of identified deficiencies
AML/CFT/CPF compliance frameworks must be capable of withstanding supervisory reviews and on-site inspections.
Common AML/CFT/CPF compliance challenges
Across the Luxembourg financial sector, institutions face similar AML/CFT/CPF compliance challenges, often driven by regulatory change, operational complexity, and increasing supervisory scrutiny.
Typical challenges include:
- translating regulatory requirements into effective controls
- maintaining consistency across business lines and jurisdictions
- overseeing delegated or outsourced AML/CFT/CPF activities
- ensuring documentation reflects actual practices
- preparing for inspections and responding to findings
Addressing these challenges requires both regulatory understanding and practical implementation.
Our AML/CFT/CPF compliance services in Luxembourg
We support Luxembourg regulated entities in establishing, reviewing, and strengthening AML/CFT/CPF compliance frameworks that are proportionate, sustainable, and aligned with supervisory expectations.
Our AML/CFT/CPF compliance services include:
- design and enhancement of AML compliance frameworks
- review of AML/CFT/CPF governance and organisational structures
- assessment of AML/CFT/CPF risk assessments and controls
- review and enhancement of policies and procedures
- oversight of delegated and outsourced AML/CFT/CPF activities
- support with remediation and supervisory findings
- preparation for regulatory interaction and inspections
Our approach focuses on practical outcomes and clear evidence of compliance.
Governance, oversight, and accountability
Supervisory expectations increasingly focus on the role of senior management and boards in AML/CFT/CPF compliance. Clear governance, meaningful reporting, and documented challenge are essential elements of an effective framework. We support institutions in strengthening governance arrangements and ensuring that AML/CFT/CPF compliance is fully embedded in management oversight and decision making processes.
Inspection readiness and ongoing compliance
AML/CFT/CPF inspections and thematic reviews assess how compliance frameworks operate in practice. Institutions must be able to demonstrate not only the existence of controls, but also their effectiveness and ongoing monitoring. We assist clients in preparing for inspections, addressing supervisory feedback, and implementing sustainable remediation measures.
How this service fits within our Anti-Financial Crime offering
AML/CFT/CPF compliance is a central component of the broader Anti-Financial Crime framework. This service closely links to financial crime risk assessments, KYC and due diligence, transaction monitoring, sanctions compliance, and governance reviews, each addressed on dedicated service pages within our Anti-Financial Crime offering.
Contact and next steps
Whether you are enhancing an existing AML/CFT/CPF framework, responding to supervisory feedback, or preparing for regulatory engagement, a structured and proportionate approach is essential in the Luxembourg environment.