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Risk of Terrorist Financing in Luxembourg

The report assesses the risks of terrorist financing (TF) in Luxembourg, particularly in relation to financial transactions and institutions.

Lone Actors and Small Terrorist Organizations: Require small financial amounts (<€10,000), mostly funded from legitimate activities.
Foreign Terrorist Fighters (FTFs): Also have small financial requirements (<€10,000) and may be self-funded or recruited through networks.
International Terrorist Organizations and Other Terrorist Actors: Require very high financial amounts.

Raising Funds: Luxembourg residents’ donations to non-profit organizations (NPOs) carrying out development and humanitarian projects abroad.
Moving Funds: Abusing Luxembourg’s services commensurate with their higher financial needs.

The report identifies the following sectors as vulnerable to TF:

Traditional Banking Products
- Offered by retail and business banking, which can be misused for cross-border transactions by lone actors, small terrorist cells, or FTFs.
Private Banking
- Due to its size, international exposure, and nature of clients (prevalence of big and potentially more sophisticated accounts).
Money Transfer Businesses (MTVs)
- Allows easy access to fast and convenient cross-border transactions, making them vulnerable to abuse by FTFs, lone actors, and small cells operating within the EU.

In 2020, retail and business banks filed the highest number of Suspicious Transaction Reports (STRs) in Luxembourg.
Private banking exposure to TF is driven by their size, international exposure, and nature of clients.