AML/CFT/CPF Remediation (Post‑Inspection) ¦ Luxembourg

AML/CFT/CPF Remediation (Post‑Inspection) ¦ Luxembourg

Restore CSSF/AED compliance fast with AML/CFT/CPF post‑inspection remediation in Luxembourg – regulator‑ready plans, implementation, reporting and sustained monitoring across the Luxembourg financial sector.

Notice

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 byconcilio et labore GmbHconcilio 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

Restore regulatory compliance quickly and sustainably after a CSSF or an AED inspection. Our focused AML/CFT/CPF post‑inspection remediation service in Luxembourg delivers risk-based and structured remediation plans, corrective action implementation, documentation for regulators and ongoing monitoring to prevent repeat findings.

Elevate your post-inspection remediation! Targeted remediation support for Luxembourg regulated entities.

Why targeted post‑inspection remediation is essential in Luxembourg

CSSF and other Luxembourg regulators expect demonstrable, timely remediation when inspection findings arise. Inadequate remediation risks fines, restrictions and reputational harm. Effective remediation addresses immediate deficiencies and fixes root causes so the same issues do not recur.

  • Meet CSSF/AED timelines and reporting expectations
  • Close inspection findings with evidence-based actions while following a risk-based approach
  • Strengthen policies, procedures, controls and governance based on CSSF regulation and guidance in the financial sector
  • Reduce ongoing anti-money laundering (AML), counter terrorist financing (CTF) and counter proliferation financing (CPF) risk and operational disruption

Our AML/CFT/CPF post‑inspection remediation methodology

We use a four‑phase, regulator‑aware approach tailored to Luxembourg entities (e.g. Luxembourg investment fund managers (IFMs), management companies, AIFMs, investment funds):

  1. Rapid diagnostic and prioritisation: Review inspection report and evidence, map impacted processes, prioritise findings by regulatory risk and operational impact.
  2. Remediation plan & governance: Draft a clear remediation plan with milestones, owners, evidence requirements and CSSF/AED reporting templates.
  3. Implementation & quality assurance: Execute fixes – policy updates, customer remediation (KYC/KYB), transaction reviews, internal controls improvement – and perform independent QA testing.
  4. Reporting & sustained monitoring: Provide regulator‑ready progress reports, train staff, implement monitoring metrics and continuous improvement routines.

Typical remediation assessment and activities we deliver

  • Customer file remediation: re‑KYC, risk‑rating updates, source of wealth documentation and file closure with audit trail
  • Policy and procedures redesign for AML/CFT/CPF aligned with Luxembourg law, national risk assessment of money laundering and CSSF/AED, as well as, AMLA/EBA guidance
  • Transaction monitoring tuning, alert investigation playbooks and retrospective reviews
  • Governance fixes: roles, delegated authorities, escalation, and compliance committee materials
  • Enhanced training for front office, compliance and back office tailored to remedial issues
  • Preparation and delivery of CSSF‑style remediation reporting and evidence packs

Deliverables and outcomes of our support services

Clients receive a pragmatic package designed to satisfy regulators and reduce risk:

  • Remediation plan with Gantt (timeline) and RACI (Responsible, Accountable, Consulted, Informed)
  • Defined evidence checklist for each finding
  • Regulator‑ready progress reports and final closure report
  • Revised AML/CFT/CPF and targeted financial sanctions policies and process maps
  • Training materials and monitoring dashboards
  • Independent validation report confirming remediation effectiveness

Why choose a localised Luxembourg approach?

Luxembourg’s financial ecosystem and CSSF/AED expectations are distinct. We combine international anti-money laundering and countering the financing of terrorism expertise with local regulatory experience, ensuring remediation aligns with CSSF/AED expectations, national law and regulations for cross‑border activities frequently encountered in Luxembourg domiciled entities.

Elevate your post-inspection remediation! Targeted remediation support for Luxembourg regulated entities.

Frequently asked questions (FAQ)

AML (anti‑money laundering) remediation focuses on preventing money laundering. CFT (counter‑financing of terrorism) remediation targets terrorism financing risks. CPF (counter proliferation financing) remediation targets financing linked to proliferation activities. Remediation projects of financial institutions frequently cover all three areas because controls overlap.
Duration depends on severity and volume of findings. Small‑scale remediation can take 4–8 weeks; medium projects 2–4 months; large cross‑border remediation may take 6–12 months with phased delivery and interim CSSF/AED reporting.
We prepare regulator‑ready reports and can support communications, but direct liaison is typically coordinated with your legal and senior management to preserve client privilege and governance. We can work alongside your legal counsel for direct engagement if required.
We focus on root‑cause fixes to ensure compliance, embed controls into daily operations of financial services, deliver targeted training to the luxembourg market and implement monitoring Key Performance Indicators (KPIs) to detect regressions of AML compliance early.
Remediation must align with the Luxembourg legal framework, notably the law of 12 November 2004 on the fight against money laundering and terrorist financing and CSSF Regulation 12-02 of 14 December 2012 (and any later amendments). Also consider relevant EU law, CSSF circulars, Financial Action Task Force (FATF) / European Banking Authority (EBA) / Anti-Money Laundering Authority (AMLA) guidance so your risk‑based approach and due diligence measures meet supervisory expectations.
Undertake customer due diligence and enhanced due diligence where risk factors indicate higher risk. This includes identification and verification of the identity of customers and ultimate beneficial owners, source/wealth checks, asset due diligence for investment exposures, and documentation to evidence decisions. Apply a risk‑based approach to target resources proportionate to the assessed laundering and terrorist financing risks.
Entities supervised by the CSSF should produce regulator‑ready evidence: a remediation plan referencing the findings, timelines (Gantt), RACI (Responsible, Accountable, Consulted, Informed), and an evidence checklist per finding. Show implemented policy changes, completed customer file remediation, transaction reviews, tuned monitoring rules, training records, and independent QA/validation demonstrating effective mitigation of the money laundering and terrorist financing risk factors.
Investment fund managers, corporate services and other Luxembourg service providers must apply the AML framework proportionate to their business. That means meeting due diligence obligations, documenting risk assessments (including national and EU risk factors), keeping up with CSSF circulars and ensuring the compliance officer and governance framework can detect and prevent misuse of the financial system for the purposes of money laundering or terrorist financing.
Bring in external AML/CFT/CPF specialists when internal capacity cannot undertake customer remediation, transaction reviews, or independent validation to supervisory standards. Notify and provide progress reports to the CSSF per the supervisory expectations and any circular clarifications; coordinate communications with legal counsel where appropriate to preserve governance and privilege while ensuring timely supervisory clarification and exchange of information across the EU if cross‑border issues arise.

How does this service fit within the broader AFC offering?

Our focused AML/CFT/CPF post‑inspection remediation service forms an important part of the broader Anti‑Financial Crime framework. This service is closely linked to AML/CFT/CPF compliance, risk assessment, KYC and CDD, transaction monitoring, and sanctions compliance, Responsable du Contrôle (RC) services, Interim Management, and the role of independent Non-Executive Directors (iNEDs) which are addressed on dedicated service pages within our Anti-Financial Crime offering.

Get started today

Start with a focused rapid assessment: we review your inspection report and sample files, then deliver an executive remediation roadmap. That roadmap provides validated timelines, resource estimates and a regulator‑ready communications template.

✒Send us a message and we’ll get back to you.
✉E-mail us at e-mail@cetl.lu.
Rest assured, your query is important to us and we will respond shortly.
☏You can also contact Bastian on +49 171 5356474. If he is unable to answer your call immediately, he will call you back.

Connect with Bastian and follow FinancialCrime.lu.

Or simply book a rewarding meeting here:

Elevate your post-inspection remediation! Targeted remediation support for Luxembourg regulated entities.