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Luxembourg AML Survey 2020

From compliance to innovation - Key challenges for the financial sector

As the world continues to respond to the COVID-19 pandemic, criminals around the world are taking advantage of the situation, finding new ways to generate illicit funds.

As such, the fight against Money Laundering and Terrorist Financing (ML/TF) remains more important than ever. The year 2020 saw a wide range of emerging ML/TF risks on a global scale, including government and private sectors’ abilities to implement Anti-Money Laundering and Counter Terrorist Financing (AML/CTF) obligations from supervision, regulation and policy reform to suspicious transaction reporting and international cooperation.

Our survey’s objective was to better understand the current AML/CTF landscape in Luxembourg in order to analyse the state of play around these topics. It also highlight the key challenges faced by the various industries in terms of AML/CTF compliance, whilst providing an industry-wide benchmarking standard for clients to measure themselves against in future.

Key Takeaways

AML/CTF environment overview

AML challenges keeping the financial sector busy:

  • Increased regulatory pressure;
  • Maintaining KYC up-to-date;
  • Manual processes in the wider AML/CTF context. The top
    three rank at the top in almost each sector, closely followed by data quality management.


On the investment side, a clear trend concerns automatisation/digitalisation, data clean-ups and CDD improvements. 

It is fair to assume that the three are interdependent and digitalisation plays a key role, but it also shows that so far there was likely more talking about it then walking the talk. 

In fact, technology is supposed to get more traction looking forward, which is not surprising given the fact that this area was less focused on it in the past.


AML/CTF related processes are an often-debated topic for outsourcing. When looking at our results it seems to have clear value in certain contexts but is also not the ‘silver bullet’ it is often referred to as. The “biggest” appetite seems to be around periodic KYC reviews and screenings.

Many respondents in Luxembourg are moving towards strategic investment in AML/CTF resources in-house, demonstrating the continued importance and critical nature of the subject matter to most. When asked how they forecast the evolution of their AML/KYC team, more than half respondents forecast that the size of their AML/CTF team will increase.

AML Governance

Strong AML governance needs awareness and the level of awareness about the importance of AML/CTF is crucial for its success. 

It is reassuring that awareness is very high at the level of Senior Management and Control functions, demonstrating a strong “tone from the top”, since the Board of Directors also score very high.

“The recent past has seen a lot of new developments and trends in the technology field and in the options available to transform and digitalise the AML/CTF environment."

Michael Weis, AML and Financial Crime Leader
AML report

Interested to receive the full report?

Our Luxembourg AML Survey 2020 main report will be released soon. If you wish to receive the full version once available, fill in the form via the link below:

Request the report here

Contact us

Michael Weis

Partner, Advisory, AML and Financial Crime leader, PwC Luxembourg

Tel: +352 49 48 48 4153

Roxane Haas

Partner, Audit, specialised in AML for the Banking industry, PwC Luxembourg

Tel: +352 49 48 48 2451

Birgit Goldak

Partner, Risk Assurance, specialised in AML for the Asset Wealth Management industry, PwC Luxembourg

Tel: +352 49 48 48 5687

Murielle Filipucci

Partner, Tax, specialised in AML and prevention of tax crimes, PwC Luxembourg

Tel: +352 49 48 48 3118

Pierre Kirsch

Partner, Tax, specialised in AML and prevention of tax crimes, PwC Luxembourg

Tel: +352 49 48 48 4031

Anthony Dault

Partner, Insurance, Assurance and Regulatory & AML Leader, PwC Luxembourg

Tel: +352 49 48 48 2380

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