Luxembourg — Country Risk Report

Luxembourg (Europe • Western Europe). Risk report as of the 19 Jun 2026 FATF plenary.

Moderate country risk, with AML/CFT effectiveness gaps. Luxembourg's country risk score is 3.0/10, placing it in the moderate-risk band. The principal score driver is AML/CFT effectiveness, contributing 2.3 of 3.0 points. Separately, the treatment overlays show that Luxembourg is not currently FATF grey- or black-listed, and that Luxembourg is not subject to comprehensive country-wide sanctions and has no direct country-level programme identified. Firms should apply additional scrutiny where exposure involves state-linked entities, restricted sectors, sensitive technology, dual-use goods or politically exposed counterparties.

Recommended treatment

Standard due diligence for most relationships, with enhanced checks where defined risk triggers are present.

At a glance

• FATF status: Not currently listed (one indicator only; it does not set the overall country risk rating by itself)
• No direct country-level sanctions programme identified; sanctions remain a legal treatment overlay and applicable lists must still be screened.
• Governance and institutions: 1.3/10
• Corruption (CPI 2025): 78/100, rank #8 of 182
• Enforcement: 1 live regulator feed; current totals are loaded from the live evidence API

Country Risk Score: 3.0/10 (Moderate)

Higher score means higher country risk (global average 5.5). Full information available. Composite score. Strong supporting evidence. Enforcement activity and CPI are context only; FATF listing and sanctions are regulatory overlays except the labelled FATF listing status used where no mutual evaluation exists.

All three underlying risk pillars are available. All three underlying risk pillars are available and weighted using the published formula. Weight sensitivity 2.8–3.2/10.

How this score was calculated

• AML/CFT effectiveness: 5.2/10 — 45% of this score
• Technical compliance: 1.1/10 — 20% of this score
• Governance and institutions: 1.3/10 — 35% of this score

Sanctions treatment: No direct programme identified. FATF treatment: none.

Principal risk drivers

• AML/CFT effectiveness: 5.2/10 × 45% = 2.3 points
• Governance and institutions: 1.3/10 × 35% = 0.5 points
• Technical compliance: 1.1/10 × 20% = 0.2 points

Mitigating factors

• Not currently on the FATF grey or black list.
• No comprehensive country-wide sanctions programme.
• Comparatively stronger corruption (1.1/10).
• Risk is concentrated in specific counterparties, sectors and transactions rather than applying uniformly.

Business impact

• Customer onboarding (Elevated): Verify ultimate beneficial ownership and control from more than one source.
• Payments and transactions (Elevated): Review transaction purpose, counterparties and the full payment routing.
• Trade and export activity (Elevated): Screen goods, end users and potential dual-use exposure.
• Corporate clients (Standard): Assess state ownership, government links and political exposure.
• Ongoing monitoring (Elevated): Alert on ownership changes, new designations and status changes.

Recommended controls

• Verify ultimate beneficial ownership using more than one reliable source.
• Identify state ownership, government influence and politically exposed persons.
• Screen entities, directors and beneficial owners against applicable sanctions lists.
• Apply enhanced review to technology, defence, telecommunications, financial services and dual-use activity.
• Document transaction purpose and source of funds where cross-border structures are complex.
• Escalate unresolved ownership opacity or adverse information to Compliance.

Enhanced due diligence triggers

• State ownership / control
• PEP involvement
• Sensitive / restricted sectors
• Opaque ownership
• Adverse media
• Dual-use goods & technology
• High-risk intermediary routing

FATF status: Not currently listed

Luxembourg is not on the FATF grey or black list as of the 19 Jun 2026 plenary.

Source details

International sanctions by issuing body

• UN: No
• EU: No
• UK: No
• US: No

No means the complete UN, UK, EU and US review found no direct country-level programme. People or organisations may still appear on sanctions lists.

Government effectiveness and rule of law (World Bank 2024, percentile)

• Government Effectiveness: 91/100
• Regulatory Quality: 84/100
• Rule of Law: 87/100

Enforcement activity

RegActions has 1 live regulator feed mapped to Luxembourg. Current action totals are loaded from the live evidence API rather than the static registry.

• CSSF — Commission de Surveillance du Secteur Financier (live feed, 2020-2026)

The composite RegActions Country Risk Score does not use enforcement volume.

Regulators and legal framework

FATF network

FATF member.

Last mutual evaluation: 2023 · report

National regulators

• CSSF — Commission de Surveillance du Secteur Financier (live feed, 2020-2026)

FIU: Egmont Group member (CRF)

Framework signals

• FATF listing: Not currently listed
• International sanctions: no direct country programme identified (legal treatment overlay remains applicable)
• BO register: Restricted (live since 2019)
• Corruption (CPI 2025): 78/100, rank #8 of 182
• Rule of law (WGI): 1.3/10 risk

Regulatory ecosystem and enforcement visibility

This evidence map is separate from Country Risk v3. It describes official mandates, publication access and RegActions coverage; it does not judge regulatory strength or add points to country risk.

Transparency Index: not scored · Evidence disposition: local-authority-evidence · Mapped official authorities: 4.

Evidence level: Level 3: Enforcement visible. The ladder uses the authority evidenceLevel schema directly and does not infer a level from a URL, site access or RegActions feed count.

1. 1. Identity confirmed — The authority and its mandate are evidenced by official directory provenance.
2. 2. Regulatory activity visible — A qualified authority-owned route has provisional dated activity in the first-page scan.
3. 3. Enforcement visible — A qualified authority-owned enforcement route has provisional dated activity in the first-page scan.
4. 4. Score eligible — Shown only when the authority evidence schema explicitly records score-eligible; no authority currently does.

Enforcement visibility: 2 authorities are classified enforcement-visible by the authority evidence schema, based on qualified authority-owned route evidence and provisional first-page month observations. This is not a validated engagement frequency.

Authorities and mandate evidence

• Central Bank of Luxembourg — Level 1: Identity confirmed · Official site reachable

  Mandates: Central bank, Prudential supervision · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

  No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  Publication candidates and qualification

  • Unqualified publication candidate: Monetary policy decisions

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

  • Unqualified publication candidate: 34/ The June 2026 Governing Council rate hike: A measured and robust decision - Blog du Gouverneur - 14.07.2026

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

  • Unqualified publication candidate: Privacy notice and cookies

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: news_or_notice · Source scope: authority-owned · Qualification: manual-review-required · Provisional scan signal: no-dated-first-page-signal · Observed months: 0 · Latest observed month: unknown

• Commissariat aux Assurances — Level 3: Enforcement visible · Official site reachable

  Mandates: Insurance · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: recent · Observed month count: 24 · Latest observed month: 2026-08.

  Provisional automated first-page date scan on an authority-owned qualified route. It is not a validated publication frequency or effectiveness measure.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  Publication candidates and qualification

  • Unqualified publication candidate: Sanctions et autres mesures administratives

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

  • Official authority-owned enforcement route: Informations dans le contexte de l’agression militaire de la Russie contre l’Ukraine

    Authority-owned and approved for the human-reviewed route contract.

    Route type: sanctions_or_penalty_list · Source scope: authority-owned · Qualification: approved-for-human-contract · Provisional scan signal: frequent-first-page-signal · Observed months: 24 · Latest observed month: 2026-08

  • Unqualified publication candidate: Sanctions financières internationales

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

• Commission de Surveillance du Secteur Financier — Level 3: Enforcement visible · Official site reachable

  Mandates: Prudential supervision, Securities, Pensions · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: recent · Observed month count: 16 · Latest observed month: 2026-02.

  Provisional automated first-page date scan on an authority-owned qualified route. It is not a validated publication frequency or effectiveness measure.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  Publication candidates and qualification

  • Official authority-owned enforcement route: Enforcement of Issuer Disclosure

    Authority-owned and approved for the human-reviewed route contract.

    Route type: enforcement_archive · Source scope: authority-owned · Qualification: approved-for-human-contract · Provisional scan signal: active-first-page-signal · Observed months: 16 · Latest observed month: 2026-02

• Financial Intelligence Unit (FIU-LUX) — Level 1: Identity confirmed · Official site reachable

  Mandates: Financial intelligence · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

  No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

Download regulatory ecosystem PDF · CSV · JSON

Sector exposure

• Banking & payments (Low): No FATF overlay and governance pillar within normal range
• Trade & export controls (Low): No direct sanctions or FATF call-for-action overlay identified
• Crypto & virtual assets (Low): No FATF overlay and effectiveness pillar within normal range
• Real estate & luxury assets (Low): Beneficial-ownership and governance signals are within normal range
• State-linked & procurement (Low): Current risk pillars show no elevated procurement signal

Derived from sanctions tier, FATF listing, World Bank WGI governance and CPI; no per-sector dataset is asserted.

Luxembourg: analysis

Luxembourg's profile is the product of exceptional governance performance. Corruption (weighted 35%) is the lowest corruption reading in the batch and among the lowest globally. Rule of law and institutions (weighted 40%) is equally strong. Voice and accountability (strong) is excellent. Political stability (strong) is the comparatively weakest domain and still firmly low risk. No FATF listing or sanctions apply. The CPI reading and an upper-decile standing on the World Bank governance indicators confirm Luxembourg's position as a flagship low-risk jurisdiction. CSSF enforcement activity reflects the breadth and depth of a major international financial centre.

Outlook

Luxembourg's status as a premier European investment funds and private banking centre means its regulatory environment continues to evolve in step with EU AML developments, including AMLA and the new AML regulation package. The risk profile is stable and well-governed. Firms should apply standard proportionate due diligence but should be alert to the jurisdiction's role as an intermediary for global capital flows, where the source-of-funds integrity of non-EU investors and fund structures warrants appropriate scrutiny.

Key watchpoints

• Monitor CSSF enforcement patterns for sectoral themes relevant to fund management, private banking and payment services.
• Track EU AMLA implementation and any impact on CSSF supervisory responsibilities as the new authority becomes operational.
• Apply source-of-funds and beneficial ownership scrutiny for fund structures and investment vehicles where ultimate investors are from higher-risk jurisdictions.
• Review developments in Luxembourg's tax and transparency frameworks as international OECD and EU standards continue to tighten.

Assessment currency

• FATF status: Not listed (as of 19 Jun 2026)
• Sanctions exposure: None identified (as of Jul 2026)
• Governance (WGI): Latest dataset incorporated (as of 2024)
• Corruption (CPI): 78/100 (as of 2025)
• RegActions assessment: Reviewed (as of 19 Jun 2026)

Public evidence layer

FATF action: none. No FATF call-for-action or increased-monitoring status was identified at the latest plenary. This does not establish low risk.

Contextual signals (not scored)

• FATF network membership: Direct FATF member (present, as of 2026-07)
• EU non-cooperative tax jurisdictions: Not listed in Annex I (absent, as of 2026-02-17)
• Egmont Group FIU: CRF (present, as of 2026-07-17)
• Beneficial-ownership register: Restricted (live since 2019) (present, as of 2026-08-23)
• Transparency International CPI: 78/100, rank 8 (present, as of 2025)

Evidence freshness

• FATF monitored-jurisdiction status: current; data 2026-06-19
• FATF mutual evaluation and follow-up ratings: current; data 2026-08-24; follow-up 2023-09; base assessment 2023-09
• World Bank governance indicators: current; data 2024
• UN, UK, EU and US sanctions regimes: current; data 2026-08-30

Contextual signals are public evidence only and do not change the current country-risk score.

Download evidence PDF · CSV · JSON

Contextual risk evidence (not scored)

These eight evidence families provide context only. They do not change the v3.1 headline score. Unavailable means no reviewed, country-comparable evidence is currently ingested; it does not mean the risk is absent.

• Organised crime: Not available. No reviewed country-level organised-crime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Fraud and cybercrime: Not available. No reviewed country-level fraud or cybercrime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Terrorism and proliferation financing: Not available. No reviewed country-comparable terrorism/proliferation threat dataset is currently checked in; FATF listing status remains a separate overlay. Candidate sources are research leads only; they have not been ingested as evidence.
• Trafficking: Not available. No reviewed country-level trafficking dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Financial secrecy and offshore exposure: Not available. No reviewed, licence-clean financial-secrecy index is currently checked in; jurisdiction type alone is not used as a proxy. Candidate sources are research leads only; they have not been ingested as evidence.
• Tax cooperation: Not listed in EU Annex I. Annex I is a political/legal tax-cooperation list, not a general AML, corruption, or country-risk score. Source
• Political stability and conflict: 84/100 WGI percentile. WGI is an institutional perception indicator, not a conflict event feed or a prediction of future violence. Source
• Beneficial ownership: Register accessible for due diligence. The Open Ownership map is a live-register snapshot and absence means no register was identified in that snapshot, not that no register exists. Source

Regional peer scores

• Bosnia and Herzegovina: 6.0/10 (High)
• Bulgaria: 5.7/10 (High)
• Azerbaijan: 5.3/10 (High)
• Hungary: 5.3/10 (High)
• Ukraine: 5.3/10 (High)
• Albania: 5.2/10 (High)

Source: FATF black & grey lists · World Bank WGI (CC BY 4.0 — World Bank WGI) · TI CPI (CC BY-ND 4.0 — Transparency International, display only)