Financial Crime World

Money Laundering Definition and Examples in Luxembourg: A Look into the Country’s Anti-Money Laundering Framework

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Luxembourg has been commended for its solid anti-money laundering (AML) and counter-terrorism financing (CFT) framework, with a good understanding of its money laundering and terrorist financing risks. However, there are areas that require improvement to further strengthen its AML/CFT framework.

Key Challenges


Insufficient Focus on Investigations and Prosecutions

There is a need for more focus on money laundering investigations and prosecutions, as well as asset recovery in Luxembourg. This is an area where the country can improve.

Risk-Based Supervision of Non-Financial Sectors

Luxembourg also needs to improve its risk-based supervision of non-financial sectors such as real estate and notaries. These sectors are vulnerable to money laundering and terrorist financing, but require more attention from authorities.

Resource Constraints

The Financial Intelligence Unit (FIU) may need to increase its resources to continue producing high-quality financial intelligence products.

Main Money Laundering Threats


According to a recent assessment by the Financial Action Task Force (FATF), Luxembourg’s main money laundering threats come from foreign predicate offences, including:

  • Tax crimes
  • Corruption
  • Fraud

The country’s banking, investment, and trust sectors are particularly vulnerable to money laundering and terrorist financing.

Prioritization of Sectors


Luxembourg’s financial supervisor, the Commission de Surveillance du Secteur Financier (CSSF), has prioritized the banking and investment sectors and uses a risk-based approach to supervision. However, more work needs to be done in other sectors such as real estate and notaries.

Domestic Cooperation and Coordination


Luxembourg’s robust domestic co-operation and coordination are key strengths, with authorities working constructively with international counterparts.

Areas for Improvement


Complex Money Laundering Cases

More work is needed to develop and communicate effective measures to prevent larger scale terrorist financing in the country’s role as an international financial centre.

Asset Recovery Efforts

Luxembourg needs to focus on improving its asset recovery efforts domestically. While it responds effectively to foreign requests for assistance in freezing, seizing, or confiscating assets related to crimes committed abroad, more work is needed to demonstrate effectiveness in this area.

Conclusion


While Luxembourg has made significant progress in combating money laundering and terrorist financing, there are areas that require improvement. By focusing on these areas, the country can further strengthen its AML/CFT framework and maintain its reputation as a reliable financial centre.