Financial Crime 2024: CSSF’s Supervision, Findings and Regulatory Developments
The CSSF continued to apply a risk‑based supervisory framework combining off‑site and on‑site measures to monitor compliance with anti‑money laundering and countering the financing of terrorism obligations.
In 2024 the authority collected quantitative and qualitative data through the annual Questionnaire on Financial Crime across all supervised sectors, implemented an API to streamline data intake and processed long‑form audit and AML/CFT reports from approved statutory auditors and internal control functions.
The CSSF placed particular emphasis on the quality of name screening, timely review of alerts, transaction monitoring effectiveness, beneficial owner identification and documentation of source of funds and wealth.
The regulator also stressed the need for clear governance of outsourced AML/CFT tasks and robust second‑line controls.
Understanding the EU’s “Best Efforts” Obligation in Sanctions Compliance: What Businesses Need to Know
Since June 2024, European Union individuals and businesses with ownership or control over entities outside the EU have been facing new responsibilities when it comes to enforcing sanctions against Russia and Belarus.
The EU requires these operators to use “best efforts” to ensure that their foreign affiliates do not undermine the effectiveness of EU sanctions — even if those affiliates are outside the EU’s legal reach.
Summary of the FATF webinar on complex Proliferation Financing and Sanctions Evasion Schemes held on July 29, 2025
The recent FATF webinar on complex proliferation financing (PF) and Sanctions Evasion Schemes presented a detailed overview of the evolving challenges and strategies used by state and non-state actors
to circumvent international sanctions related to weapons of mass destruction (WMD) programs.
The discussion was anchored around a comprehensive report developed by a team of experts from 20 governments and international organizations, highlighting over 40 case studies that reveal the sophisticated
methods proliferators use to evade financial controls.
The webinar aimed to enhance understanding among both public authorities and private sector participants about the current threat landscape and effective mitigation strategies.
Circular No. 792 ter enhances customer identification and verification requirements for AML/CFT compliance among AED-Supervised Professionals in Luxembourg
Circular No. 792 ter, issued on July 28, 2025, updates the obligations of professionals subject to the control and supervision of the Administration de l’Enregistrement, des Domaines et de la TVA (AED)
in Luxembourg in the fight against money laundering and terrorist financing.
This circular reinforces the requirements for identifying and verifying the identity of individual customers, in line with the amended law of November 12, 2004, which governs anti-money laundering
and counter-terrorism financing (AML/CFT) measures.
EU Sanctions: When Does a Shareholder’s Stake Lead to Freezing of Company Assets? – Insights from the EM System UAB Case
On July 3, 2025, Advocate General Tamara Ćapeta delivered her opinion in the significant case C-84/24 before the Court of Justice of the European Union (CJEU).
The core question: Is it sufficient for the freezing of a company’s bank accounts that a sanctioned person holds exactly 50% of its shares?
