AML/CFT/CPF Risk Assessment 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
The AML/CFT/CPF risk assessment forms the foundation of the AML/CFT/CPF framework for Luxembourg regulated entities. Supervisory expectations focus on whether institutions maintain a documented, risk-based assessment that accurately reflects their business model, customer base, products, services, and geographic exposure. An effective AML/CFT/CPF risk assessment in Luxembourg supports informed decision-making, underpins the design of controls, and provides a clear basis for governance and oversight. It must be regularly reviewed and updated to reflect changes in risk exposure and regulatory expectations.
The Luxembourg AML/CFT/CPF risk assessment environment
Luxembourg’s supervisory approach emphasises substance, proportionality, and management ownership of the AML/CFT/CPF risk assessment.
Regulated entities are expected to:
- identify and assess inherent AML/CFT/CPF risks across all relevant dimensions
- apply clear and consistent risk criteria
- document methodologies, assumptions, and outcomes
- link risk assessment results to controls and mitigation measures
- ensure regular review and senior management involvement
Risk assessments must be capable of withstanding supervisory review and inspection.
Common AML/CFT/CPF risk assessment challenges
Institutions often face challenges in ensuring that AML/CFT/CPF risk assessments remain meaningful and operationally relevant over time.
Typical areas of supervisory focus include:
- overly generic or static risk assessments
- unclear methodologies or scoring logic
- insufficient linkage between risks and controls
- lack of senior management engagement
- inadequate documentation and evidence trails
Addressing these challenges requires a structured and defensible approach.
Our AML/CFT/CPF risk assessment services in Luxembourg
We support Luxembourg regulated entities in developing, reviewing, and enhancing AML/CFT/CPF risk assessments that are proportionate, well-documented, and aligned with supervisory expectations.
Our services include:
- design and review of AML/CFT/CPF risk assessment methodologies
- assessment of inherent and residual risks
- support with documentation and rationale
- linkage of risk assessment outcomes to control frameworks
- facilitation of management workshops and reviews
- preparation for supervisory interaction and inspection
Our focus is on practical usability and supervisory defensibility.
Governance and management ownership
Supervisory expectations in Luxembourg place strong emphasis on management ownership of the AML/CFT/CPF risk assessment. Senior management and boards are expected to understand key risks, challenge assumptions, and approve outcomes. We support institutions in embedding AML/CFT/CPF risk assessment into governance processes and ensuring that outputs support effective oversight and decision making.
Inspection readiness and ongoing review
Supervisory inspections frequently assess AML/CFT/CPF risk assessments in detail, including methodologies, assumptions, and evidence of review. Institutions must be able to demonstrate that risk assessments are current, robust, and actively used. We assist clients in preparing for inspections, addressing findings, and establishing sustainable review processes.
How this service fits within our Anti-Financial Crime offering
AML/CFT/CPF risk assessment underpins the broader Anti-Financial Crime framework and links directly to AML/CFT/CPF compliance, KYC and CDD, transaction monitoring, sanctions compliance, and governance. These areas are covered on dedicated service pages within our Anti-Financial Crime offering.
Contact and next steps
If you are reviewing your AML/CFT/CPF risk assessment, addressing supervisory feedback, or strengthening your risk-based approach, a structured and proportionate methodology is essential.