Building Trust Through Cooperation: How the ABBL–CRF–CSSF PPP Strengthens Luxembourg’s AML/CFT Framework

A collective effort for a common goal

The fight against financial crime can only succeed if every actor plays their part — and works together to reach that goal. The PPP was built on these principles.

Through regular meetings, representatives from the public and private sectors discuss current threats, share anonymised examples, and explore concrete solutions. These exchanges help translate regulatory expectations into operational practice — ensuring that compliance is not just about rules, but about understanding and anticipation.

Turning dialogue into impact

Over the past four years, the PPP has achieved tangible outcomes for the industry:

• Red-flag indicators and sectoral guidance that help institutions refine their risk assessments and strengthen their AML frameworks;
• Enhanced mutual understanding between the CRF, CSSF and the private sector, improving cooperation and responsiveness;
• A reinforced culture of trust across the ecosystem, enabling open, constructive discussions on sensitive topics.

This trust is the cornerstone of the PPP’s success: participants can discuss sensitive topics in a safe and constructive setting, leading to faster identification of emerging risks and more proportionate, risk-based AML/CFT measures — ensuring that efforts remain both effective and pragmatic.
The initiative has also helped to ensure that AML/CFT efforts in Luxembourg remain both effective and proportionate — focused where the risks are highest, and always guided by a balanced, risk-based approach.

For ABBL members, these outcomes translate into better guidance, clearer expectations, and more operational coherence across the financial sector.

A model for the European AML framework

As the European Union rolls out its new AML architecture — with the upcoming AMLR, AMLD6 and the creation of AMLA — the Luxembourg PPP stands out as a practical model of structured cooperation.
It shows that public-private collaboration is not just a concept but a working reality that delivers measurable results and strengthens Europe’s collective resilience against financial crime.

Building on this experience, the ABBL advocates for such institutionalised dialogue between authorities and the private sector within the future AMLA. Embedding a permanent, trust-based exchange between authorities and the private sector at the European level would strengthen the collective capacity to detect risks early and respond effectively.

The ABBL is proud to contribute to this reflection and to share Luxembourg’s experience to support a European model of cooperation that places trust, pragmatism and partnership at its core.

Looking ahead

The partnership is now entering a more strategic phase, with new areas of work already taking shape.

Building on the trust and momentum established over the past years, the PPP is developing joint threat analysis exercises and preparing Luxembourg’s next FATF evaluation through its 2026–2027 roadmap. These initiatives will deepen the collective understanding of financial crime risks and further anchor cooperation as a driver of intelligence and innovation.

The ABBL continues to play a pivotal role — ensuring that its members’ perspectives and operational realities remain at the heart of this process.

For the ABBL and its members, this is the essence of the partnership: building trust and intelligence together — to create tangible impact, for all and for each.