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.
Luxembourg Reports Ongoing Progress in Combating Financial Crime
Regulatory Framework and Supervision
Luxembourg has implemented comprehensive measures to combat money laundering and terrorist financing, with the Administration de l’enregistrement, des domaines et de la TVA (AED) playing a crucial role in supervising non-financial sectors.
The AED’s Financial Crime Division, staffed by 17 professionals (p.259), focuses on prevention through guidance, conferences, document reviews, and on-site inspections of professionals under its supervision.
Luxembourg also maintains a registry of trusts and fiduciary arrangements in accordance with the law of July 10, 2020, providing transparency regarding beneficial owners.
EU AI Act: AML and Fraud Detection AI Not ‘High-Risk’
Did you know that AI systems used specifically for Anti-Money Laundering (AML) and fraud detection in financial services are not classified as ‘high-risk’ under the EU AI Act?
This distinction is important for the financial and compliance sectors! Here’s the detailed scoop:
Analysis of EU AI Office stakeholder consultations on defining AI systems and prohibited applications
The Commission published a report analyzing stakeholder feedback from public consultations on the AI Act’s regulatory obligations regarding the definition of AI systems and prohibited AI practices, highlighting calls for clearer technical definitions and concrete examples of prohibited activities.
Second thematic review on the use of Artificial Intelligence in the Luxembourg financial sector
The Banque centrale du Luxembourg (BCL) and the Commission de Surveillance du Secteur Financier (CSSF) published today the second thematic report on the use of Artificial Intelligence (AI) in Luxembourg’s financial sector.
Building on a similar study conducted in 2023, this report examines the evolving adoption of AI within the sector, with a particular focus on the growing prevalence and associated risks of Generative AI (GenAI).
The report presents the findings of a survey conducted between June and August 2024, encompassing Investment Firms (IFs), Authorised Investment Fund Managers (IFMs/AIFMs), Credit Institutions (B), E-money Institutions (EMIs),
and Payment Institutions (PIs). This expanded scope represents more than a threefold increase in participation compared to the previous survey, which focused solely on Credit Institutions, E-money Institutions and Payment Institutions.
