AML/CFT/CPF Policies & Procedures 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
AML/CFT/CPF policies and procedures are a fundamental component of the AML/CFT/CPF framework for Luxembourg regulated entities. Supervisory expectations focus on whether documentation is tailored, up to date, and reflective of how AML/CFT/CPF controls operate in practice, rather than generic or purely theoretical. Effective AML/CFT/CPF policies and procedures provide clear guidance to staff, support consistent implementation of controls, and enable institutions to evidence compliance during supervisory reviews and inspections.
The Luxembourg AML/CFT/CPF documentation environment
Luxembourg’s supervisory approach places strong emphasis on the quality and relevance of AML/CFT/CPF documentation.
Regulated entities are expected to:
- maintain comprehensive and clearly structured AML/CFT/CPF policies
- document procedures that reflect actual operating practices
- align documentation with risk assessments and governance arrangements
- ensure regular review and approval by appropriate management bodies
- provide clear evidence of implementation and awareness
Documentation must be capable of supporting effective oversight and supervisory scrutiny.
Common documentation challenges
Institutions often face challenges in ensuring that AML/CFT/CPF policies and procedures remain effective and fit for purpose over time.
Typical supervisory focus areas include:
- overly generic or copied documentation
- misalignment between policies and operational practices
- outdated procedures not reflecting current risks or controls
- unclear roles and responsibilities
- insufficient documentation of governance and escalation
Addressing these challenges requires a structured and risk-based documentation approach.
Our AML/CFT/CPF policies and procedures services in Luxembourg
We support Luxembourg regulated entities in drafting, reviewing, and enhancing AML/CFT/CPF policies and procedures that are proportionate, practical, and aligned with supervisory expectations.
Our services include:
- review and enhancement of AML/CFT/CPF policies and procedures
- alignment of documentation with risk assessments and controls
- clarification of roles, responsibilities, and escalation paths
- support with governance, approval, and review processes
- assistance with remediation and inspection preparation
Our focus is on documentation that supports effective implementation and oversight.
Governance, approval, and ownership
Supervisory expectations require AML/CFT/CPF policies and procedures to be formally approved and actively owned by senior management. Documentation should support governance and enable management bodies to understand and oversee AML/CFT/CPF risks. We assist institutions in strengthening governance frameworks around AML/CFT/CPF documentation, including approval, review, and change management processes.
Inspection readiness and supervisory review
AML/CFT/CPF policies and procedures are frequently reviewed in detail during supervisory inspections. Institutions must be able to demonstrate that documentation is current, applied in practice, and supported by training and controls. We support clients in preparing documentation for supervisory review and addressing identified weaknesses.
How this service fits within our Anti-Financial Crime offering
AML/CFT/CPF policies and procedures underpin the broader Anti-Financial Crime framework and link directly to AML/CFT/CPF compliance, risk assessment, KYC and CDD, transaction monitoring, sanctions compliance, and governance. These services are covered on dedicated pages within our Anti-Financial Crime offering.
Contact and next steps
If you are reviewing your AML/CFT/CPF documentation, addressing supervisory feedback, or preparing for inspection, a structured and proportionate approach is essential.