AML/CFT Conference: Taking Stock of Regulatory Priorities and Operational Challenges

A turning point for the AML/CFT framework

Opening the conference, Jonathan Hug (ABBL) underlined why such a discussion was particularly relevant today. The AML/CFT framework has reached a turning point: the key question is no longer whether regulation exists, but how effective we can be in its implementation. At the same time, the supervisory landscape is evolving, notably with the upcoming role of the European Anti-Money Laundering Authority (AMLA), which will introduce a new dimension to the European supervisory architecture.

Supervisory priorities and Luxembourg’s reputation

The conference featured several speakers from the CSSF, who shared insights on supervisory priorities and expectations for the financial sector. During his intervention, Claude Marx, Director General of the CSSF, highlighted the importance of preserving Luxembourg’s strong reputation as an international financial centre. Maintaining high compliance standards remains essential not only for the integrity of the financial system but also to provide confidence to the major international financial groups operating in Luxembourg. He also highlighted the constructive and ongoing collaboration with the ABBL to facilitate bank account openings for legal entities.

CSSF representatives also stressed the strategic role played by Chief Compliance Officers (CCOs) within financial institutions. Beyond regulatory compliance, CCOs contribute actively to risk management and to the definition of institutions’ risk appetite, making them key actors in the governance of financial institutions.

The importance of industry engagement

Another key message from CSSF representatives was the importance for the financial industry to actively participate in public consultations on regulatory developments. These consultations offer valuable opportunities for institutions to share their expertise and operational experience. Participants were encouraged to make full use of the channel offered by the ABBL to consolidate and relay industry feedback.

A broad financial crime framework

Discussions also highlighted the broad scope of today’s financial crime framework. As several CSSF speakers stressed, the topic goes far beyond traditional anti-money laundering considerations and also encompasses counter-terrorist financing (CFT), the fight against proliferation financing, the implementation of international financial sanctions, as well as the fight against corruption — an area receiving particular attention from authorities and financial institutions alike.

These distinctions are particularly important in the context of the Financial Action Task Force (FATF)’s work, with Luxembourg’s next mutual evaluation report expected in 2030, when the financial sector will be assessed as a stand-alone subject.

Cooperation and information sharing

Throughout the conference, speakers from the CSSF, but also from the Cellule de Renseignement Financier (CRF-SIU), emphasised the importance of communication and information sharing between stakeholders. Effective cooperation requires communication to be both sufficient and necessary, ensuring that relevant information can be shared appropriately while respecting legal constraints.