AML/CFT/CPF Inspections Preparation
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
AML/CFT/CPF inspections and supervisory reviews are a key element of regulatory oversight in Luxembourg. Regulated entities are expected to demonstrate that their AML/CFT/CPF frameworks are not only formally documented, but effectively implemented and actively overseen by senior management. Preparation for AML/CFT/CPF inspections requires a structured approach that focuses on governance, risk assessment, control effectiveness, and the quality of documentation and evidence available to supervisors.
The Luxembourg inspection environment
Supervisory inspections in Luxembourg increasingly focus on substance and practical effectiveness.
Institutions are expected to:
- demonstrate a clear and documented risk-based AML/CFT/CPF framework
- evidence management ownership and oversight
- show effective operation of controls in practice
- provide complete, consistent, and accessible documentation
- demonstrate timely remediation of identified issues
Inspection readiness requires coordination across functions and clear accountability.
Common inspection preparation challenges
Institutions often face challenges when preparing for AML/CFT/CPF inspections, particularly where frameworks have evolved over time or where responsibilities are distributed across functions.
Typical supervisory focus areas include:
- consistency between documentation and actual practices
- quality of governance and management reporting
- effectiveness of KYC & CDD, monitoring, and escalation processes
- clarity of roles and responsibilities
- evidence of remediation and follow-up
Addressing these challenges requires early preparation and structured review.
Our AML/CFT/CPF inspection preparation services
We support Luxembourg regulated entities in preparing for AML/CFT/CPF inspections and supervisory reviews in a structured and proportionate manner.
Our services include:
- assessment of AML/CFT/CPF frameworks against supervisory expectations
- review of documentation, evidence, and audit trails
- identification of gaps and prioritisation of remediation
- support with remediation planning and implementation
- preparation of management and key function holders
- assistance during supervisory interaction where appropriate
Our approach focuses on inspection readiness and sustainable improvement.
Governance and management engagement
Supervisory expectations place strong emphasis on the role of senior management and boards during inspections. Management bodies are expected to understand AML/CFT/CPF risks, oversee remediation, and engage constructively with supervisors. We support institutions in strengthening management engagement and preparing key stakeholders for supervisory interaction.
Post inspection remediation and follow-up
Effective inspection preparation includes planning for remediation and follow-up. Institutions are expected to address findings in a timely and structured manner and to evidence progress. We assist clients in managing post inspection remediation and maintaining regulatory confidence.
How this service fits within our Anti-Financial Crime offering
Inspection preparation draws on all elements of the Anti-Financial Crime framework, including AML/CFT/CPF compliance, risk assessment, KYC & CDD, transaction monitoring, sanctions compliance, audit preparation, and governance. These services are covered on dedicated pages within our Anti-Financial Crime offering.
Contact and next steps
If you are preparing for an AML/CFT/CPF inspection or supervisory review, a structured and proportionate approach is essential in the Luxembourg environment.