Publication
Luxembourg has officially released its updated National Risk Assessment (NRA 2025) on money laundering, marking a key milestone in the country’s ongoing efforts to strengthen its anti-money laundering and counter-terrorist financing (AML/CFT) framework. Coordinated by the Ministry of Justice and mandated by the Comité de prévention du blanchiment et du financement du terrorisme, this assessment reflects a collaborative effort involving a broad range of public authorities, private-sector stakeholders, and civil society actors.
The NRA 2025 focuses exclusively on the national money laundering risk landscape, with a separate update on terrorist financing scheduled for release at a later date. The analysis is based on data from 2020 to 2023 and captures the state of play as at the end of 2023. It follows the same methodological framework as previous assessments, identifying inherent risks, assessing existing mitigation measures, and determining the residual risk levels across key sectors.
Key findings of the NRA 2025
- Luxembourg remains primarily exposed to money laundering threats stemming from foreign predicate offences, owing to its role as an international financial hub. Fraud and forgery, tax crimes, and corruption continue to pose the most significant external threats.
- Domestic exposure is comparatively limited, reflecting Luxembourg’s low crime rate. However, fraud and forgery, theft (both simple and aggravated), and drug trafficking are identified as the main domestic risks.
- Vulnerabilities are linked to sectors that are susceptible to misuse for money laundering purposes, notably the financial sector, non-financial professions, legal persons, and legal arrangements.
- Within the financial sector, banks, investment firms, e-money and payment institutions, certain specialised professionals, virtual asset service providers, and the life insurance sub-sector all present a high level of inherent risk. Effective mitigation measures reduce their residual risk to medium.
- In the non-financial sector, legal and accounting professions also display a high inherent risk, with the exception of auditors and bailiffs, whose risks are rated medium. Mitigation measures bring most of these risks down to medium, while auditors' residual risk is considered low.
- Regarding legal persons and arrangements, the NRA 2025 draws on the 2022 vertical risk assessment. Legal arrangements are assessed as having the highest inherent and residual risk, followed by commercial companies.
Strengthening risk understanding and response
With the publication of the NRA 2025, Luxembourg reaffirms its commitment to a dynamic, risk-based AML/CFT framework. The assessment is intended not only as a strategic policy instrument but also as a practical reference for professionals subject to AML obligations. By providing updated risk analyses, case studies, and an adaptable risk assessment methodology, the NRA supports both national coordination and effective risk mitigation at the institutional level.
This latest assessment also follows Luxembourg’s positive evaluation by the Financial Action Task Force (FATF) in 2023, which recognised the strength of the country’s AML/CFT framework and its sound understanding of the risks at play. The NRA 2025 builds on that momentum, ensuring Luxembourg continues to evolve in line with emerging threats and international best practices.
The NRA 2025 alongside further publications on AML/CFT by the Ministry of Justice can be found here.
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