Luxembourg has updated its money laundering risk map: what businesses should look out for now

In May 2025, Luxembourg officially launched its updated National Risk Assessment (ENR 2025) on anti-money laundering (BC), a key document that identifies current and future threats to the country's financial system. The development was led by the Ministry of Justice and coordinated by the BC/FT Prevention Committee. The process involved both government agencies and representatives of the private and non-profit sectors. The document captures the situation as of the end of 2023.

ENR 2025 was the third such assessment, following the 2018 version and the 2020 revision. It focuses exclusively on money laundering risks. A separate assessment on terrorist financing will be presented at a later date and will cover the period 2021-2024.

The main purpose of the ENR is to help governments, regulators and businesses apply a risk-based approach, allocating resources more accurately and building preventive measures where risks are really high. The document also serves as a practical tool for professionals who are required to comply with BC/FT requirements: companies can use it to develop their own internal risk assessments and adjust processes.

ENR 2025 offers an adaptable analysis methodology, contains about two dozen new case studies, and thematic boxes on issues that require special attention.

Main conclusions of ENR 2025

The analysis showed that the main threat to money laundering comes from abroad. This is due to Luxembourg's role as an international financial centre. Among the most significant external threats are tax and financial fraud, forgery and corruption.

In contrast, internal risks (domestic threats) are lower and are predominantly related to offences committed within the country: mainly theft, drug trafficking and fraud.

The strongest vulnerability is recorded in several sectors:

• The financial sector - banks, investment companies, e-money providers, life insurance, crypto services - are all categorised as sectors with a "high level of inherent risk". Due to control and supervisory measures, the residual risk has been reduced to "medium".
• Non-financial sector - lawyers and accountants are also in the "high risk" zone, with the exception of auditors and bailiffs. The measures taken reduce the overall risk to "medium", and even to "low" in the case of auditors.
• Legal structures and companies - trusts and foundations and for-profit companies are recognised as the most vulnerable, especially if there is a lack of transparency about beneficial ownership.

These findings are supported by the results of the GAFI (Group Against Money Laundering International) assessment published in September 2023. GAFI recognised that Luxembourg has a "robust anti-money laundering system" and a "deep understanding of the risks".

What's next?

ENR 2025 is designed not only to reflect the current situation, but also to become a platform for continuous updating of risk knowledge. This is necessary given the growing complexity of financial schemes and the emergence of new threats, including those arising from the use of digital assets.

For the private sector, this means: time to review internal procedures, staff training and monitoring systems. The document will serve as a reference point in preparation for regulatory inspections and risk audits.

In an increasingly regulated environment, having an up-to-date risk assessment is not a formality, but a matter of strategic business resilience. ENR 2025 now sets a new benchmark.