AML/CFT/CPF for Banks 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
Banks operating in Luxembourg are subject to heightened AML/CFT/CPF supervisory expectations due to the nature, scale, and complexity of their activities. Effective AML/CFT/CPF frameworks are expected to address a broad range of financial crime risks, including money laundering, terrorist financing, proliferation financing, and sanctions exposure, while remaining fully embedded in governance and day-to-day operations. Supervisory focus extends beyond formal compliance to the effectiveness of controls, quality of oversight, and the ability of senior management to demonstrate informed control over AML/CFT/CPF risks.
The Luxembourg banking AML/CFT/CPF environment
Luxembourg regulated banks operate within a supervisory framework aligned with EU AML/CFT/CPF legislation and local expectations that emphasise substance and accountability.
Banks are expected to:
- maintain comprehensive, risk-based AML/CFT/CPF frameworks
- perform robust customer due diligence (CDD) and ongoing monitoring
- operate effective transaction monitoring and escalation processes
- ensure clear governance and accountability across the organisation
- evidence timely remediation of identified weaknesses
AML/CFT/CPF frameworks must be capable of withstanding supervisory review and on-site inspections.
Common AML/CFT/CPF challenges for banks
Banks in Luxembourg face AML/CFT/CPF challenges driven by complex customer bases, cross-border activity, and evolving regulatory expectations.
Typical supervisory focus areas include:
- quality and consistency of customer due diligence (CDD)
- effectiveness of transaction monitoring systems
- management of higher-risk customers and products
- governance and senior management oversight
- inspection readiness and remediation capability
Addressing these challenges requires a structured and bank specific approach.
Our AML/CFT/CPF services for banks in Luxembourg
We support Luxembourg regulated banks in designing, reviewing, and enhancing AML/CFT/CPF frameworks that are proportionate, effective, and aligned with supervisory expectations.
Our services include:
- review and enhancement of bank AML/CFT/CPF frameworks
- AML/CFT/CPF risk assessments and control evaluations
- customer due diligence (CDD) and transaction monitoring reviews
- governance and organisational assessments
- support with remediation and supervisory findings
- preparation for CSSF inspections and reviews
Our approach combines regulatory understanding with practical implementation experience.
Governance, oversight, and accountability
Supervisory expectations place significant responsibility on bank boards and senior management to oversee AML/CFT/CPF risks effectively. Clear governance structures, meaningful reporting, and documented challenge are essential. We support banks in strengthening governance arrangements and ensuring that AML/CFT/CPF oversight is embedded at the appropriate management levels.
Inspection readiness and supervisory interaction
AML/CFT/CPF inspections of banks in Luxembourg are often detailed and wide-ranging. Banks must be able to demonstrate effective operation of AML/CFT/CPF controls and timely remediation of identified issues. We assist banks in preparing for inspections, engaging with supervisors, and implementing sustainable improvements.
How this service fits within our Anti-Financial Crime offering
AML/CFT/CPF for banks is closely linked to KYC & CDD, transaction monitoring, sanctions compliance, AML/CFT/CPF audit preparation, and governance reviews. These areas are addressed on dedicated service pages within our broader Anti-Financial Crime offering.
Contact and next steps
If you are reviewing your bank’s AML/CFT/CPF framework, responding to supervisory feedback, or preparing for inspection, a structured and proportionate approach is essential.