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pc nid 93287 Jun 17, 2026 tojuri@vixio.com Luxembourg News and Media - Commission de Surveillance du Secteur Financier financial services
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Luxembourg Financial Services Regulator Clarifies De-Risking Practices and Money Laundering Risk Management Expectations

On June 16, 2026, the Commission de Surveillance du Secteur Financier (CSSF), Luxembourg's financial services regulator, published a communiqué addressing de-risking practices and money laundering and terrorist financing (ML/FT) risk management. The CSSF issued the guidance following reports from individuals and legal entities experiencing difficulties opening bank accounts in Luxembourg, which some credit institutions attributed to burdensome ML/FT prevention requirements. The CSSF clarified that it expects supervised entities to manage—not avoid—ML/FT risks through effective internal frameworks for risk identification and mitigation. The regulator emphasised that higher-risk business relationships are not prohibited and that supervised entities cannot generally ban entire categories of clients, products, or services unless expressly mandated by applicable laws, including the Law of November 12, 2004 on combating money laundering and terrorist financing and CSSF Regulation No 12-02. The CSSF stressed that financial inclusion and sound ML/FT risk management are compatible objectives and should be pursued proportionately, consistent with guidance from the Financial Action Task Force (FATF). The regulator noted that professionals may apply simplified due diligence to low-risk populations rather than rigid identification requirements. The CSSF distinguished between CSSF-imposed de-risking—implemented only when ML/FT risks become unmanageable—and strategic business decisions to exit unprofitable customer segments. The regulator does not intervene in institutional business models or individual onboarding decisions. The CSSF also emphasised that clients must cooperate by providing adequate documentation and information on fund origins. The European Banking Authority (EBA) and EU Anti-Money Laundering Authority (AMLA) are mandated to issue joint guidelines by July 2027 addressing de-risking measures and compliance requirements under Regulation (EU) 2024/1624.

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Luxembourg’s Commission de Surveillance du Secteur Financier Clarifies De-Risking Practices and Money Laundering Risk Management Expectations

On June 16, 2026, Luxembourg’s Commission de Surveillance du Secteur Financier (CSSF) published a notice addressing de-risking practices and money laundering and terrorist financing (ML/FT) risk management. The CSSF issued the notice following reports from individuals and legal entities experiencing difficulties opening bank accounts in Luxembourg, which some credit institutions attributed to burdensome ML/FT prevention requirements. The CSSF clarified that it expects supervised entities to manage, rather than avoid, ML/FT risks through effective internal frameworks for risk identification and mitigation. The regulator emphasised that higher-risk business relationships are not prohibited and that supervised entities cannot generally ban entire categories of clients, products or services unless expressly mandated by applicable laws, including the Law of November 12, 2004 on combating money laundering and terrorist financing and CSSF Regulation No 12-02 of December 2012 . The CSSF stressed that financial inclusion and sound ML/FT risk management are compatible objectives and should be pursued in a proportionate manner, consistent with guidance from the Financial Action Task Force (FATF). The regulator noted that professionals may apply simplified due diligence to low-risk populations rather than rigid identification requirements. The CSSF distinguished between CSSF-imposed de-risking, implemented only when ML/FT risks become unmanageable, and strategic business decisions to exit unprofitable customer segments. The CSSF also emphasised that the identification and mitigation of money laundering and terrorist financing (ML/TF) risks by professionals also requires the active cooperation of potential clients. The CSSF notes that the European Banking Authority and the European Anti-Money Laundering Authority (AMLA) are due to issue joint guidance by July 10, 2027 on the measures that can be taken by credit and financial institutions to ensure compliance with AML/CTF rules, including with regard to business relationships most affected by disengagement practices.