Anti-Money Laundering and CFT/CPF Risk Assessment ¦ Luxembourg

Anti-Money Laundering and CFT/CPF Risk Assessment ¦ Luxembourg

Luxembourg AML/CFT/CPF risk assessments for funds, ManCos and financial entities – CSSF/AED‑aligned, regulator‑ready and tailored to EU AML rules.

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

Delivering actionable AML, CFT and CPF risk assessments aligned with Luxembourg regulation, EU AML Directives and competent authorities expectations for investment fund managers (ManCos and AIFMs), investment funds (UCITS, AIFs, RAIFs), banks, payment institutions, and other obliged entities.

Boost your AML/CFT/CPF risk assessment readiness! Targeted advisory support for Luxembourg regulated entities.

Why a dedicated AML/CFT/CPF risk assessment in Luxembourg?

Luxembourg’s financial sector operates under strict supervision by the CSSF/AED and EU AML frameworks. A localised AML/CFT/CPF risk assessment identifies country-, client- and product-level vulnerabilities, reduces regulatory breach risk and demonstrates a documented risk-based approach to supervisors.

  • Regulatory alignment: CSSF/AED guidance, Luxembourg law and EU AML Directives
  • Targeted risk scoring by client type, product, channel and geography
  • Clear remediation plans and governance improvements
  • Enhanced ability to evidence compliance during inspections and audits

Policymakers rely on FATF (Financial Action Task Force) recommendations to reduce vulnerabilities to money laundering and terrorist financing and to monitor evolving risk factors.

Our services for financial sector professionals

Risk Assessment

Comprehensive AML/CFT/CPF risk assessments: risk universe mapping, scoring methodology, heatmaps and prioritized risk register tailored to your business model.

Policies & Procedures

Drafting and updating AML/CFT/CPF policies, customer due diligence (CDD/EDD) procedures and transaction monitoring rules to meet CSSF/AED expectations. Boards overseeing the collective investment sector should ensure their organizations contribute to the fight against money laundering by maintaining effective due diligence measures.

Training & Governance

Targeted training for senior management, compliance teams and front office on risk indicators, reporting obligations and sanctions screening, with reference to, inter alia, CSSF Regulation 12-02 and the law of 12 November 2004.

How we conduct AML/CFT/CPF risk assessments – proven 6-step approach

  1. Scoping: Identify obliged entity activities, products, delivery channels and legal/regulatory requirements in Luxembourg.
  2. Data collection: Client segments, products, transaction flows, screening logs, KYC files and internal controls.
  3. Risk identification: Map threats, vulnerabilities and potential CPF (proliferation financing) vectors, considering local and international sanctions.
  4. Risk scoring & prioritization: Consolidated scoring model covering inherent and residual risk with heatmap visualization.
  5. Remediation planning: Practical controls, policy updates, system tuning and resource recommendations prioritized by impact and effort.
  6. Reporting & monitoring: Deliver regulator-ready report, KPIs and a repeatable monitoring cadence for ongoing risk management.

Sector expertise for Luxembourg institutions and investment funds under the supervision of the CSSF and AED

We work with:

  • Fund managers and AIFMs
  • Investment funds (UCITS, AIFs, RAIFs)
  • Banks and private banks
  • Payment & e-money institutions
  • Corporate service providers & trustees
  • Fintechs and crypto-asset service providers

Key outputs you will receive

  • Executive summary for the board and compliance committee
  • Regulator-ready AML/CFT/CPF risk analysis and business-wide risk assessment report
  • Prioritized remediation roadmap with estimated timelines and owners
  • Updated risk appetite statements, policy templates, standard operating procedures and training materials
  • Ongoing monitoring framework and KPI dashboard

Why choose us

  • Local regulatory knowledge – experience with CSSF expectations and Luxembourg Law on AML/CFT
  • Practical remediation – focused on controls you can implement quickly and efficiently
  • Senior subject-matter experts with financial sector and investigative backgrounds
  • Confidential, evidence-based reporting suitable for internal audit and supervisory review

Frequently asked questions (FAQ) ¦ AML risk assessment

CPF (Counter-Proliferation Financing) covers financial flows that enable the development or spread of weapons of mass destruction. Integrating CPF into AML/CFT assessments helps detect sanction evasion and high-risk supply chain financing that standard AML controls might miss.
Small to medium firms: 4–6 weeks. Larger or more complex institutions: 8–14 weeks, depending on data availability and scope.
Yes. Our reports are designed to demonstrate a documented risk-based approach, remediation actions and governance – all items CSSF/AED and auditors review during on-site inspections.
We provide both advisory remediation roadmaps and hands-on implementation support, including policy drafting, system tuning, and staff training.
The Financial Intelligence Unit supplies timely intelligence and typology reports; the Ministry of Justice translates these into legal actions, policy guidance and a national risk assessment of money laundering; together they exchange information, conduct joint risk assessments, and coordinate follow-up to mitigate laundering and terrorist financing risks.
Luxembourg’s framework combines national legislation, CSSF circulars (including those implementing the amended law of 12 November 2004 and the Grand-ducal Regulation of 1 February 2010 providing details on certain provisions), and international standards. Key elements address money laundering and terrorism financing risks, provisions of the amended law, and legislation and regulations applicable at national level. The CSSF (Commission de Surveillance du Secteur Financier) issues circulars to clarify supervision of the CSSF and set out provisions for supervised entities such as Luxembourg investment fund managers and alternative investment funds.
Professionals must implement adequate internal management requirements and professional obligations, including risk‑based policies and procedures (customer due diligence, record keeping, transaction monitoring). Enhanced due diligence is required where the sub‑sector risk assessment or specific risk level indicates higher risk. Information accompanying transfers of funds and other reporting obligations must be followed to ensure combating money laundering and terrorist financing and to meet CSSF supervision expectations.
Authorities and supervised entities perform sub‑sector risk assessments to identify risks of money laundering and financing measures tied to terrorism. Based on the assessed risk level, entities apply proportionate measures: standard customer due diligence for normal risk, and enhanced due diligence for higher‑risk clients, jurisdictions or products. These measures help align internal controls with international standards and the specific context of collective investment activities.
The CSSF provides supervisory guidance through circulars and enforces supervision of the CSSF‑supervised sector. At the European level, the European Commission and international bodies set broader AML/CTF standards that influence national legislation and amended laws. Together, national regulators, CSSF circulars, and European/international standards create the compliance environment for the Luxembourg financial sector.

How does this service fit within the broader AFC 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 AML/CFT/CPF inspections preparation. These areas are covered on dedicated service pages within our Anti-Financial Crime offering.

Get started today

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.

✒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.

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Boost your AML/CFT/CPF risk assessment readiness! Targeted advisory support for Luxembourg regulated entities.