AML/CFT Stakeholders
AML/CFT Bodies
Two key bodies play a significant role in combating money laundering and terrorist financing (AML/CFT) at the national level:
Interministerial Steering Committee for the Fight Against Money Laundering and Terrorist Financing
The Government Council Decree of 8 May 2024 established an interministerial steering committee for the fight against money laundering and terrorist financing.
As a formal structure created by government act (in Council), its missions are to:
- Propose to the government the key strategic directions and priorities of the national policy against money laundering and terrorist financing,
- Propose to the government measures to mitigate risks of money laundering and terrorist financing, as well as related data protection issues,
- Report to the government on progress in implementing the national strategy against money laundering and terrorist financing.
Committee for the Prevention of Money Laundering and Terrorist Financing
Under the authority of the Minister responsible for Combating Money Laundering and Terrorist Financing, the ML/TF Prevention Committee is established.
As an operational body instituted by the amended Law of 12 November 2004, on combating money laundering and terrorist financing, Article 9-1 quater, its mission is to:
- Develop, coordinate, and evaluate national AML/CFT policies,
- Coordinate work on updates to national risk assessments (NRA),
- Serve as a multidisciplinary roundtable for exchanges between public authorities, supervisory bodies (CSSF, AED, CAA, etc.), the private sector, and other stakeholders (professionals, associations) to prevent money laundering and terrorist financing risks, ensuring a coordinated national response,
- Implement a risk-based approach, adapt measures according to identified risks, and ensure supervisory authorities have the necessary means to fulfil their mandates.
The composition and functioning of the Committee are determined by the Grand-Ducal Regulation of 11 June 2025 on the composition and functioning of the Committee for the Prevention of Money Laundering and Terrorist Financing.
AML/CFT Stakeholders
The stakeholders involved in AML/CFT are presented in the following subsections. They include ministries, the Financial Intelligence Unit (CRF-FIU), judicial and law enforcement authorities, supervisory and self-regulatory bodies, and other actors.
Alongside institutional stakeholders, private sector entities are also subject to AML/CFT obligations as obliged entities. These entities must refer to the provisions of Article 2 of the Law of 12 November 2004 on combating money laundering and terrorist financing.
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