Outsourced AML/CFT/CPF Activities 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
Outsourcing of AML/CFT/CPF-related activities is common in the Luxembourg financial sector and can support operational efficiency and access to specialised expertise. However, outsourcing does not transfer regulatory responsibility. Regulated entities remain fully accountable for the effectiveness, governance, and oversight of outsourced AML/CFT/CPF activities. Supervisory expectations focus on how outsourced AML/CFT/CPF activities are selected, governed, monitored, and controlled in practice, and on the ability of management to demonstrate effective oversight at all times.
The Luxembourg outsourcing and AML/CFT/CPF environment
Luxembourg’s supervisory approach places strong emphasis on governance, risk assessment, and accountability in outsourcing arrangements.
Regulated entities are expected to:
- clearly define the scope of outsourced AML/CFT/CPF activities
- assess and document outsourcing related risks
- maintain clear contractual and governance arrangements
- exercise ongoing oversight and performance monitoring
- ensure effective escalation and remediation mechanisms
Outsourced AML/CFT/CPF arrangements must be capable of withstanding supervisory review and inspection.
Common outsourcing challenges
Institutions often face challenges in ensuring that outsourced AML/CFT/CPF activities remain effective and compliant over time, particularly where multiple providers or cross-border arrangements are involved.
Typical supervisory focus areas include:
- clarity of roles and responsibilities
- adequacy of oversight and reporting
- consistency of AML/CFT/CPF standards applied by service providers
- documentation of challenge and follow-up
- contingency and exit planning
Addressing these challenges requires a structured and well-governed outsourcing framework.
Our outsourced AML/CFT/CPF services in Luxembourg
We support Luxembourg regulated entities in establishing, reviewing, and strengthening outsourced AML/CFT/CPF arrangements that are proportionate, transparent, and aligned with supervisory expectations.
Our services include:
- assessment of arrangements for the outsourcing of AML/CFT/CPF activities
- support with outsourcing risk assessments
- design of governance and oversight frameworks
- review of reporting, escalation, and performance monitoring
- support with remediation of identified weaknesses
- preparation for supervisory reviews and inspections
Our approach focuses on maintaining regulatory control while enabling effective use of external resources.
Governance, oversight, and accountability
Effective outsourcing of AML/CFT/CPF activities requires clear governance and active oversight by senior management. Institutions are expected to understand how outsourced activities operate in practice and to challenge providers where necessary. We support institutions in strengthening oversight structures, reporting mechanisms, and documentation that evidence management control.
Inspection readiness and ongoing monitoring
Supervisory inspections increasingly assess outsourced AML/CFT/CPF arrangements in detail. Institutions must be able to demonstrate effective oversight, clear accountability, and timely remediation of issues identified at service provider level. We assist clients in preparing for inspections and establishing sustainable monitoring processes.
How this service fits within our Anti-Financial Crime offering
Outsourced AML/CFT/CPF activities are closely linked to AML/CFT/CPF compliance, risk assessment, KYC & CDD, transaction monitoring, sanctions compliance, AML/CFT/CPF Officer oversight, and AML/CFT/CPF audit preparation. These services are addressed on dedicated pages within our broader Anti-Financial Crime offering.
Contact and next steps
If you are outsourcing AML/CFT/CPF activities, reviewing existing arrangements, or preparing for supervisory inspection, a structured and proportionate approach is essential in the Luxembourg environment.