AML/CFT/CPF for PSF & FinTech 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
Professionals of the Financial Sector (PSFs) and FinTechs in Luxembourg operate in a rapidly evolving regulatory and technological environment. AML/CFT/CPF frameworks for these entities are expected to be risk-based, well-governed, and capable of addressing financial crime risks arising from innovative products, digital channels, and outsourcing arrangements. Supervisory expectations focus on the effectiveness of controls, governance over delegated activities, and the ability of management to demonstrate informed oversight of AML/CFT/CPF risks.
The Luxembourg PSF and FinTech AML/CFT/CPF environment
Luxembourg regulated PSFs and FinTechs are subject to EU AML/CFT/CPF requirements and local supervisory expectations that emphasise proportionality, substance, and accountability.
Entities are expected to:
- maintain AML/CFT/CPF frameworks aligned with their business model and technology
- perform robust customer due diligence (CDD) and ongoing monitoring
- manage risks arising from outsourcing and third-party arrangements
- ensure clear governance and allocation of responsibilities
- evidence ongoing monitoring and timely remediation
AML/CFT/CPF arrangements must be capable of withstanding supervisory review and inspection.
Common AML/CFT/CPF challenges for PSFs and FinTechs
PSFs and FinTechs often encounter AML/CFT/CPF issues relating to digital onboarding, cross-border services and dependence on third-party providers.
Typical supervisory focus areas include:
- adequacy of digital KYC and onboarding controls
- oversight of outsourced AML/CFT/CPF and IT functions
- effectiveness of transaction monitoring in technology-driven models
- governance and senior management involvement
- documentation and inspection readiness
Addressing these challenges requires a tailored and technology-aware approach.
Our AML/CFT/CPF services for PSFs and FinTechs in Luxembourg
We support PSFs and FinTechs in designing, reviewing, and enhancing AML/CFT/CPF frameworks that are proportionate, effective, and aligned with supervisory expectations.
Our services include:
- design and enhancement of AML/CFT/CPF frameworks for PSFs and FinTechs
- AML/CFT/CPF risk assessments reflecting digital and outsourcing risks
- review of KYC, onboarding, and monitoring processes
- oversight frameworks for outsourced and third-party functions
- review of AML/CFT/CPF policies, procedures, and governance
- support with remediation and CSSF inspections
Our approach balances regulatory requirements with operational and technological realities.
Governance, outsourcing, and oversight
Outsourcing is often central to PSF and FinTech operating models. Supervisory expectations place strong emphasis on governance, oversight, and control of outsourced AML/CFT/CPF relevant activities. We support entities in establishing clear oversight arrangements, reporting mechanisms, and escalation processes that are proportionate and clearly documented.
Inspection readiness and supervisory engagement
Supervisory inspections increasingly assess how AML/CFT/CPF controls operate within technology-driven and outsourced environments. PSFs and FinTechs must be able to demonstrate effective governance, oversight, and remediation capability. We assist with inspection preparation, supervisory interaction, and sustainable improvement of AML/CFT/CPF arrangements.
How this service fits within our Anti-Financial Crime offering
AML/CFT/CPF for PSFs and FinTechs is closely linked to AML/CFT/CPF compliance, risk assessment, KYC & CDD, transaction monitoring, sanctions compliance, AML/CFT/CPF audit preparation, and governance support. These areas are addressed on dedicated service pages within our broader Anti-Financial Crime offering.
Contact and next steps
If you are reviewing your AML/CFT/CPF framework, responding to supervisory feedback, or preparing for inspection as a PSF or FinTech, a structured and proportionate approach is essential.