KYC & CDD Services 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
Know Your Customer (KYC) and Customer Due Diligence (CDD) are core elements of the AML/CFT/CPF framework for Luxembourg regulated entities. Supervisory expectations focus on the consistent application of identification and verification measures, risk-based customer classification, and the ability to demonstrate that due diligence processes are effective in practice. KYC and CDD obligations apply across the financial sector, including banks, investment funds, management companies, alternative investment fund managers (AIFMs), PSFs, and FinTechs. Institutions are expected to implement due diligence frameworks that are proportionate to their business activities and customer risk profile, while remaining aligned with supervisory expectations in Luxembourg.
The Luxembourg KYC and CDD environment
Luxembourg’s supervisory approach emphasises substance, documentation, and accountability.
Regulated entities are expected to:
- apply clear customer identification and verification standards
- perform risk-based customer classification
- implement enhanced due diligence for higher risk customers and structures
- conduct ongoing monitoring and periodic review
- maintain complete and accessible documentation
KYC and CDD arrangements must be capable of withstanding supervisory review and inspection.
Common KYC and CDD challenges
In practice, institutions often face challenges in translating regulatory requirements into effective and sustainable KYC and CDD processes. These challenges may be driven by operational complexity, delegation models, or evolving regulatory expectations.
Typical areas of focus include:
- consistency of KYC standards across business lines and jurisdictions
- quality and completeness of customer files
- oversight of outsourced or delegated KYC activities
- documentation of risk assessments and decisions
- management of higher risk customers
Addressing these challenges requires both regulatory understanding and practical implementation experience.
Our KYC & CDD services in Luxembourg
We support Luxembourg regulated entities in designing, reviewing, and enhancing KYC and CDD frameworks that are risk-based, operationally effective, and aligned with supervisory expectations.
Our services include:
- assessment and enhancement of KYC and CDD frameworks
- review of customer identification and verification processes
- evaluation of customer risk classification and enhanced due diligence
- support with ongoing monitoring and periodic review processes
- review of oversight arrangements for delegated KYC activities
- improvement of policies, procedures, and documentation
Our focus is on practical solutions that support compliance and operational efficiency.
Governance, oversight, and documentation
Effective KYC and CDD frameworks require clear governance and oversight. Senior management is expected to understand customer risk exposure, challenge due diligence arrangements where necessary, and ensure that controls remain appropriate. Clear documentation and evidence trails are essential to demonstrate compliance during supervisory reviews and inspections.
Inspection readiness and remediation
Supervisory inspections frequently assess KYC and CDD practices in detail. Institutions must be able to demonstrate that due diligence measures are applied consistently and that identified weaknesses are addressed in a timely manner.
We support inspection readiness by helping clients:
- assess current KYC and CDD arrangements
- identify gaps and inconsistencies
- strengthen documentation and controls
- prepare relevant stakeholders for supervisory interaction
How this service fits within our Anti-Financial Crime offering
KYC and CDD services form a central part of the broader Anti-Financial Crime framework. This service is closely linked to AML/CFT/CPF compliance, customer risk assessment, transaction monitoring, sanctions compliance, and governance reviews, each addressed on dedicated service pages within our Anti-Financial Crime offering.
Contact and next steps
If you are reviewing your KYC and CDD framework, addressing supervisory feedback, or enhancing oversight of due diligence activities, a structured and proportionate approach is essential.