AML/CFT/CPF Audit Preparation 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.
concilio et labore GmbH is not authorised to act as an auditor and does not perform audit services; however, it supports institutions in preparing for audits.
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
Preparation for AML/CFT/CPF audits and independent reviews is a key element of an effective AML/CFT/CPF framework for Luxembourg regulated entities.
Supervisory expectations focus on whether AML/CFT/CPF controls are regularly and independently assessed, and whether identified weaknesses are addressed in a timely and sustainable manner. Institutions must therefore ensure they are properly prepared for audit and independent review activities.
In Luxembourg, AML/CFT/CPF audit expectations go beyond formal checklist exercises. Supervisory practice increasingly focuses on the effectiveness of controls, governance arrangements, and the practical day‑to‑day operation of AML/CFT/CPF frameworks across the organisation. Adequate preparation is essential to meet these expectations.
The Luxembourg AML/CFT/CPF audit environment
Luxembourg’s supervisory framework places a strong emphasis on the importance of audits and independent reviews in ensuring the effectiveness of AML/CFT/CPF controls.
Regulated entities are expected to be able to demonstrate that they:
- perform regular, risk-based AML/CFT/CPF audit or review activities
- ensure sufficient independence and expertise of reviewers
- assess both design and operational effectiveness of controls
- clearly document findings and recommendations
- monitor and evidence remediation actions
Preparation for AML/CFT/CPF audits must ensure that these expectations are met and that relevant evidence is readily available.
Common AML/CFT/CPF audit challenges
Institutions often face challenges when preparing for AML/CFT/CPF audits and independent reviews, particularly in complex or evolving environments.
Typical areas of supervisory focus include:
- scope and depth of AML/CFT/CPF audit reviews
- consistency of findings and grading
- linkage between risk assessment and audit planning
- quality of documentation and supporting evidence
- effectiveness and timeliness of remediation
Addressing these challenges requires a structured and risk-based preparation approach.
Our AML/CFT/CPF audit preparation services in Luxembourg
We support Luxembourg regulated entities in preparing for AML/CFT/CPF audits and independent reviews in a way that is proportionate, well-documented, and aligned with supervisory expectations.
Our services focus on readiness and include:
- review of AML/CFT/CPF frameworks in light of audit and supervisory expectations.
- support in preparing documentation and evidence for AML/CFT/CPF audits
- pre-audit gap assessments and readiness checks
- assistance in clarifying roles, responsibilities, and governance arrangements
- support in structuring and prioritising remediation actions
- preparation for interactions with audit functions and reviewers
We do not perform audit activities. Our role is limited to preparation, support, and advisory services.
Governance, independence, and reporting readiness
Effective preparation for AML/CFT/CPF audits requires clear governance, independence, and reporting structures. Senior management and boards are expected to receive clear and meaningful information on AML/CFT/CPF audit outcomes and remediation status. We support institutions in preparing reporting frameworks and management information so that audit results can be addressed efficiently and oversight responsibilities can be fulfilled.
Inspection readiness and supervisory expectations
Supervisory inspections often evaluate the adequacy and effectiveness of AML/CFT/CPF audit and independent review arrangements. Institutions must be able to demonstrate that audit activities are risk-based, appropriately scoped, and lead to effective remediation. We assist clients in preparing their AML/CFT/CPF audit arrangements, documentation, and evidence to align with supervisory expectations and regulatory reviews.
How this service fits within our Anti‑Financial Crime offering
Preparation for AML/CFT/CPF audits and independent reviews forms an important part of the broader Anti‑Financial Crime framework. This service is closely linked to AML/CFT/CPF compliance, risk assessment, KYC and CDD, transaction monitoring, and governance arrangements, which are addressed on dedicated service pages within our Anti-Financial Crime offering.
Contact and next steps
If you are preparing for an AML/CFT/CPF audit, responding to supervisory feedback, or strengthening your audit readiness, a structured and proportionate preparation approach is essential.