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Preparing for the next era of AML in Luxembourg - Are you ready for AMLA and the EU single rulebook?

PwC's AMLA Center of Excellence
PwC's AMLA Center of Excellence

The European Union is entering a new era of financial crime prevention. With the establishment of the Anti-Money Laundering Authority (AMLA) and the introduction of the EU AML Package, obliged entities across Europe - and particularly in Luxembourg’s highly international financial centre - face a profound regulatory shift.

From July 2027 onwards, the new AML Regulation (AMLR) as well as related Regulatory Technical Standards will apply directly in all Member States. They will replace national laws and regulations. This means a reshaping of expectations on governance, customer due diligence, transaction monitoring, sanctions screening, reporting, and the use of innovative technologies. 

Luxembourg, as a major financial hub, is heavily affected due to its large fund and banking industries.

For Luxembourg entities, this transformation brings both challenges and opportunities: greater scrutiny, higher expectations, but also the possibility to harmonise frameworks, increase efficiency, and strengthen risk management.

PwC Luxembourg supports financial institutions, asset managers, funds, PSFs, insurers, fintechs and crypto-asset service providers in understanding these changes and transforming their AML/CTF frameworks to meet the new EU-wide standards effectively, efficiently and tech-enabled, with confidence.

EU AML Package at a glance

The EU AML Package is a comprehensive reform designed to modernise and harmonise the fight against money laundering and terrorist financing across the European Union. It consists of four key pillars:

A directly applicable regulation introducing a unified, EU-wide set of AML/CTF rules. It sets detailed requirements for customer due diligence, beneficial ownership, high-risk third countries, internal controls, reporting obligations, and the use of advanced data and technological tools.

A directive focused on strengthening national supervision and cooperation. It sets rules for:

  • Supervisory powers and cooperation mechanisms.
  • Access to information for FIUs and competent authorities.
  • Sanctions and enforcement.
  • Risk assessments and oversight of non-financial obliged entities.

The new EU Anti-Money Laundering Authority will:

  • Directly supervise certain high-risk cross-border entities.
  • Coordinate national supervisors (e.g., CSSF, CAA).
  • Develop Regulatory Technical Standards (RTS) and guidelines.
  • Ensure harmonised implementation across the EU.

AMLA will start direct supervision in 2028, with preparatory phases beforehand.

Enhanced requirements for tracing transfers of funds and crypto-assets (travel rule), applying to CASPs under MiCA. 
This significantly increases transparency for crypto transactions across the EU.

Together, these pillars introduce the first truly harmonised AML framework in Europe, reducing national divergences and strengthening supervisory convergence.

What changes for Luxembourg

  • Direct regulation vs transposition: AMLR is a regulation, so Luxembourg must apply it as-is, unlike previous directives which allowed national interpretation. This is also true for a host of Regulatory Technical Standard (RTS). They will impact a systematic change of your AML/CTF governance, policies and procedures framework as well as possible impact on your data and systems in place. Your employees will need to be educated and embrace the change. 
  • Crypto sector inclusion: Luxembourg’s growing crypto and fintech sectors will face stricter AML obligations under AMLR.
  • Central beneficial ownership register: AMLR mandates enhanced transparency and access to beneficial ownership data, reinforcing Luxembourg’s existing register.
  • Supervisory shift: AMLA will oversee certain high-risk entities directly, reducing CSSF’s exclusive supervisory role in some cases.
  • Fund industry concerns: Luxembourg’s investment fund sector (via ALFI) is actively engaging with EU institutions to shape upcoming Regulatory Technical Standards (RTS) and ensure proportionality.

How PwC Luxembourg can help

AML/CTF/sanction readiness and impact checks

We support you in analysing your status quo regarding the current EU AML regulation and future guidelines and deriving appropriate measures for optimisation.

AML/CTF/sanction implementation

Based on the impact assessment, we support you in planning and executing on your implementation: AML/CTF/CPF risk and governance, policies and procedures framework, operations, systems and data, and people.

Remediation - Governance and KYC

We support you in the remediation of the gaps identified to the updated risk and governance. and policy, procedure framework. We further support you in remediating your KYC files in a well organised, efficient remediation program.

AML/CTF monitoring and screening

The AMLA will issue technical standards that will be relevant for monitoring and screening. We advise you holistically and independently on the optimisation of existing tools and the use of the latest technologies.

AML/CTF internal controls framework and compliance monitoring plan

We support you in documenting your internal control framework mapping money laundering and terrorist financing risk to appropriate controls and translating it into a holistic compliance monitoring plan, ensuring compliance and effectiveness.

AML/CTF Managed Services and on-going KYC support

We support you with staff-trained AML/CTF on an ongoing basis or as an when you need it to deal with peak activity (such as monitoring or KYC or RC Support Services) so your team can concentrate on daily core functions.

AML/CTF training courses

We support you in the preparation and implementation of training courses in all areas of money laundering prevention with a special focus on the requirements of the AMLA and the EU.

Network Excellence Center cross-border, blog, updates, newsletter

Luxembourg's financial landscape is global, cross-border, and interconnected. To support our clients with the most up-to-date insights and practical implementation guidance, PwC Luxembourg works closely with the PwC EMEA Financial Crime Network, the Global AML Excellence Center, and our EU Regulatory Hub.

This gives our clients access to:

Real-time updates on AMLA developments, EU-wide supervisory expectations, and emerging best practices from other Member States.

Dedicated knowledge for banking, funds, asset servicing, payments, insurance, fintech, and virtual-asset sectors - with benchmarks and peer-comparisons across Europe.

Ongoing analysis from our experts on EU AML Package, Luxembourg regulatory expectations, AMLA technical standards, sector-specific impacts, and upcoming RTS/ITS.

Regular updates summarising:

  • AMLA communications and consultations.
  • Draft and final Regulatory Technical Standards (RTS/ITS).
  • CSSF/FIU circulars.
  • Supervisory themes and enforcement trends.

If you’d like to receive upcoming Flash News and invitations to PwC Luxembourg’s AML‑related events, roundtables and knowledge‑sharing sessions, simply indicate your interest using the form below. You’ll gain access to periodic updates covering key EU and Luxembourg AML developments, insights from PwC’s AML surveys, as well as upcoming training courses, webinars and industry working groups in collaboration with professional associations.

Stay informed of AML developments

Contact us

Birgit Goldak

Partner, Broader Assurance and AML Services, PwC Luxembourg

Tel: +352 49 48 48 5687

Email

Cécile Moser

Partner, Broader Assurance and AML Services, PwC Luxembourg

Tel: +352 62133 56 17

Email

Michael Weis

Advisory Partner, Forensics & Anti-Financial Crime Leader, PwC Luxembourg

Tel: +352 49 48 48 4153

Email
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