Overview

When the role of conducting officer is vacant, under-strength or requires specialist capability for a limited period, appointing an experienced interim conducting officer ensures regulatory continuity and the effective oversight of Anti-Financial Crime (AFC) responsibilities. In Luxembourg’s supervisory environment, interim appointees must demonstrate competence, have a clear mandate, and be able to maintain governance and control over AML/CFT/CPF, sanctions, and related financial crime risks.

Discuss interim management services Targeted advisory support for Luxembourg regulated entities

The Luxembourg conducting officer context

The CSSF, AED, and other supervisors expect conducting officers and senior managers to:

• understand and own the entity’s financial crime risk profile
• ensure frameworks are proportionate to the business model and complexity
• maintain clear allocation of responsibilities and escalation channels
• evidence active oversight, challenge, and timely remediation
• be available and accountable during supervisory interaction

An interim conducting officer must be able to step into these expectations immediately, provide continuity of oversight, and support the management body in meeting supervisory requirements.

When interim conducting officer support is needed

Typical scenarios include:

• unexpected departure, illness or suspension of a conducting officer or senior manager
• pending permanent recruitment where regulatory continuity is required
• periods of heightened supervisory scrutiny or inspection requiring strengthened senior oversight
• remediation programmes or complex projects (e.g., AML/CFT/CPF remediation, sanctions uplift, transaction monitoring redesign) requiring senior leadership with AFC expertise
• governance weaknesses identified by internal audit or regulators needing immediate corrective leadership

Our interim conducting officer services in Luxembourg

We provide experienced, regulatory-aware interim conducting officer services for Luxembourg regulated entities. Appointments are tailored to scope, duration, and regulatory sensitivities and focus on restoring or maintaining effective AFC governance and oversight.

Core services include:

• acting as conducting officer with clear, documented mandate and delegation limits
• immediate review of AML/CFT/CPF, sanctions and financial crime governance and control posture
• stabilising oversight of key function holders and outsourced providers (e.g., AML/CFT/CPF Officer, compliance, transfer agents, sanctions screening)
• leading remediation programmes and supervising delivery of regulatory commitments
• ensuring robust management information, escalation, and board reporting on AFC matters
• representing management in supervisory interactions and inspections where appropriate
• knowledge transfer and support for recruitment/onboarding of a permanent conducting officer

Practical and regulatory-aligned approach

Interim conducting officer appointments follow a pragmatic, evidence-based approach designed for rapid impact:

• swift diagnostic to identify priority regulatory and operational risks
• focused, short-term action plan with clear deliverables and timelines
• strengthened management information (MI) and documented oversight to enable management bodies to demonstrate control
• clear exit plan with handover documentation and continued advisory support if required

Governance, accountability and supervisory considerations

Interim conducting officers must meet fit and proper criteria and operate under documented delegations and governance.

We ensure:

• contractual clarity on responsibilities, limits and reporting lines
• alignment with the entity’s internal governance and the expectations of the CSSF, AED, and other relevant supervisors
• transparent documentation of decisions and escalation to boards and committees
• support for board-level oversight to evidence continuity and supervisory readiness

When an interim conducting officer is not just “cover”

Regulators assess whether interim arrangements deliver substantive oversight, not merely nominal presence. We combine regulatory experience with hands-on delivery to ensure decisions are evidenced, governance is active, and the entity can demonstrate capable leadership during inspections or regulatory inquiries.

How this service fits within our broader AFC offering

Interim conducting officer support integrates with our services in AML/CFT/CPF compliance, AML/CFT/CPF Officer support, remediation delivery, transaction monitoring, sanctions compliance, and CSSF/AED inspection preparation – providing continuity across governance and operational areas.

Contact and next steps

If you need immediate, regulatory-aware interim management to stabilise AFC governance, manage remediation, or prepare for supervisory engagement, an experienced conducting officer with Luxembourg market knowledge is essential.

Discuss interim management services Targeted advisory support for Luxembourg regulated entities