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pc nid 93870 Jul 09, 2026 tojuri@vixio.com Luxembourg Publications and data – CSSF horizon scanning
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Luxembourg's Financial Services Commission Imposes Administrative Fine on Electronic Money Institution for Anti-Money Laundering Violations

On March 2, 2026, the Commission de Surveillance du Secteur Financier (CSSF) imposed an administrative fine of EUR 12,000 on PingPong Europe S.A., an electronic money institution authorised under the Law of November 10, 2009 on payment services. The fine, representing less than one percent of the institution's total annual turnover as of December 31, 2021, resulted from an on-site inspection conducted between October 2022 and October 2023 covering anti-money laundering and counter-terrorism financing (AML/CFT) compliance. The CSSF identified multiple breaches of AML/CFT professional obligations. PingPong Europe failed to file Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) to the Financial Intelligence Unit (FIU) in three cases where suspicious indicators were detected, including two involving fraudulent activities and one involving a predicate tax offence. Additionally, the institution returned funds in two cases before its Compliance Officer determined whether reporting to the FIU was required, violating obligations to refrain from executing suspicious transactions until the FIU is informed. The CSSF also found inadequate recordkeeping practices, preventing the institution from retrieving copies of SARs and STRs sent to the FIU in 2020 and 2021. Furthermore, PingPong Europe's AML/CFT supervisory systems were inadequate for its high client volume, failing to properly distinguish between blocked, terminated, or refused business relationships, and unable to identify incomplete client files or retrieve customer residence information for beneficial owners of legal entity clients. The CSSF imposed the fine under Article 2-1(1) of the Law of November 12, 2004 on combating money laundering and terrorist financing, as amended, considering the gravity and duration of breaches, the institution's financial situation, and its level of cooperation. The CSSF noted as an aggravating factor that PingPong Europe provided incorrect information in its response. However, the institution acknowledged findings and implemented corrective measures following the inspection. The CSSF published this decision on a nominative basis on July 8, 2026, in accordance with Article 8-6(1) of the AML/CFT Law.

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Luxembourg's Commission de Surveillance du Secteur Financier Imposes €12,000 on PingPong Europe for AML Violations

In a decision dated March 2, 2026, the Commission de Surveillance du Secteur Financier (CSSF) imposed an administrative fine of €12,000 on PingPong Europe S.A., an electronic money institution (EMI), for non-compliance with professional obligations related to anti-money laundering and counter-terrorism financing (AML/CTF). The CSSF identified multiple breaches of AML/CTF professional obligations, under the Law of 12 November 2004 on the fight against money laundering and terrorist financing and CSSF Regulation No 12-02 of 14 December 2012 , following an on-site inspection between October 2022 and October 2023. The EMI failed to file suspicious activity and transaction reports with the Financial Intelligence Unit (FIU) in three cases where suspicious indicators were detected, including two involving fraudulent activity and one involving a predicate tax offence. Additionally, the institution returned funds in two cases before its compliance officer determined whether reporting to the FIU was required, thereby violating its obligation to refrain from executing suspicious transactions until the FIU is informed. The CSSF also found inadequate recordkeeping practices, preventing the institution from retrieving copies of the reports sent to the FIU in 2020 and 2021. The CSSF also found that the EMI's AML/CTF supervisory systems were inadequate for its high client volume, failing to properly distinguish among blocked, terminated or refused business relationships, and unable to identify incomplete client files or retrieve customer residence information for beneficial owners of legal-entity clients.