Luxembourg updates its national money laundering risk assessment

Luxembourg has completed its 2025 National Risk Assessment (NRA 2025) on money laundering (ML), under the direction of the Ministry of Justice and the coordination of the Comité de prévention BC/FT. This update builds on previous assessments (2018 and 2020), using data from 2020 to 2023, and focuses specifically on ML risks, with a separate assessment for terrorist financing to follow. The main aim is to adapt national understanding and management of ML/TF risks in line with evolving threats, allowing authorities and professionals to prioritize resources effectively and implement a risk-based approach. The NRA 2025 highlights that Luxembourg’s principal ML threats originate from crimes committed abroad due to its international financial center status, with fraud, forgery, tax crimes, and corruption as main external risks. Domestic ML exposure remains low given the country’s low crime rate. Sectors with higher inherent risks include banks, investment firms, electronic money institutions, payment institutions, certain non-financial professions, and complex legal structures. Mitigation measures generally reduce these risks. The report also incorporates new case studies and thematic analyses to better guide professionals.

Key Points:

  • NRA 2025 covers ML risks in Luxembourg with data from 2020–2023; TF risk assessment will be updated separately.
  • Main ML threats stem from foreign crimes (fraud, tax offenses, corruption); domestic risk is much lower.
  • Highest-risk sectors: banking, investment, payments, virtual asset providers, life insurance, legal/accounting professions (except auditors).
  • Legal entities and complex structures present the highest inherent and residual risks among all categories.
  • Mitigation efforts reduce most sector risks to “medium,” with audit professionals at “low.”
  • The approach allows for targeted resource allocation and simplified measures where risks are lower.
  • NRA 2025 serves as both a national overview and a practical tool for professionals’ own risk assessments.
  • Luxembourg’s AML/CFT regime is recognized as robust by the FATF’s 2023 mutual evaluation report.

The full 2025 National Risk Assessment is available on the Ministry of Justice website.

Watch the video if you are interested in a short summary of the 2025 National Risk Assessment.

Notice: This video was produced using AI technology. The audio content is entirely original and created by Bastian Schwind-Wagner, while the visual representation through the personalized avatar has been generated using AI to enhance the presentation.