Financial Crime Framework 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
A structured and well-governed financial crime framework is a central supervisory expectation for Luxembourg regulated entities. Institutions are expected to maintain integrated arrangements covering money laundering, terrorist financing, proliferation financing, sanctions, and other financial crime risks, aligned with their business model and risk profile. Supervisory focus extends beyond individual controls to how the overall financial crime framework operates in practice. This includes governance, risk assessment, controls, reporting, and the ability of senior management to demonstrate informed oversight.
The Luxembourg financial crime framework environment
Luxembourg’s supervisory approach emphasises proportionality, consistency, and accountability in the design and operation of financial crime frameworks.
Regulated entities are expected to:
- maintain a clear and documented financial crime framework
- integrate AML/CFT/CPF, sanctions, and related controls coherently
- align risk assessment, controls, and governance
- ensure clear roles and responsibilities across functions
- evidence ongoing monitoring and remediation
Frameworks must be capable of withstanding supervisory review and inspection.
Common framework design challenges
Institutions often face challenges in establishing or maintaining effective financial crime frameworks, particularly in complex or evolving environments.
Typical supervisory focus areas include:
- fragmented or siloed control structures
- unclear governance and accountability
- weak linkage between risk assessment and controls
- inconsistent documentation and reporting
- limited evidence of senior management oversight
Addressing these challenges requires a structured and integrated approach.
Our financial crime framework services in Luxembourg
We support Luxembourg regulated entities in designing, reviewing, and enhancing financial crime frameworks that are proportionate, coherent, and aligned with supervisory expectations.
Our services include:
- design and enhancement of financial crime frameworks
- integration of AML/CFT/CPF, sanctions, and related controls
- review of governance and organisational structures
- alignment of risk assessment and control activities
- support with documentation and reporting
- assistance with remediation and inspection preparation
Our approach focuses on practical effectiveness and sustainable governance.
Governance, oversight, and accountability
Effective financial crime frameworks rely on strong governance and clear accountability. Supervisory expectations place responsibility on senior management and boards to understand financial crime risks and oversee control effectiveness. We support institutions in strengthening governance structures, reporting lines, and documented challenge.
Inspection readiness and ongoing effectiveness
Supervisory inspections increasingly assess financial crime frameworks holistically. Institutions must be able to demonstrate that frameworks operate effectively across all relevant risk areas and are subject to ongoing review. We assist clients in preparing for inspections, addressing findings, and implementing sustainable improvements.
How this service fits within our Anti-Financial Crime offering
Financial crime frameworks form the backbone of the broader Anti-Financial Crime approach. This service integrates closely with AML/CFT/CPF compliance, risk assessment, KYC and CDD, transaction monitoring, sanctions compliance, AML/CFT/CPF audit preparation, and governance support, each covered on dedicated service pages within our Anti-Financial Crime offering.
Contact and next steps
If you are establishing, reviewing, or enhancing your financial crime framework, a structured and proportionate approach is essential in the Luxembourg environment.