Luxembourg implements the AMLD6 directive and fights the risks of virtual IBANs

In response to a parliamentary enquiry by MP Sven Clement (Piratepartei), Finance Minister Gilles Roth (CSV) and Justice Minister Elisabeth Margue (CSV) presented an updated roadmap for combating money laundering and terrorist financing.

EU Directive AMLD6 (2024/1640) is to be implemented into Luxembourg law in stages: article 74 by July 2025, articles 11-15 by July 2026 and article 18 by July 2029. However, as the Ministers explained, some of the provisions have already been implemented. In particular, the concept of "legitimate interest" has been reintroduced in the legislation on the register of beneficiaries (RBE and RFT).

A working group at the Ministry of Justice, together with the Luxembourg Business Register, is already working on amendments to the law of 13 January 2019 and a draft law will be presented in the second half of 2025.

The problem of virtual IBAN accounts is seen as a current threat. These accounts are used in fraud and money laundering schemes. The Luxembourg Financial Intelligence Service (CRF) together with the CSSF participates in a working group under the auspices of the European Banking Authority (EBA), which issued a detailed report in May 2024.

Despite this, the CRF acknowledges that it is currently impossible to accurately track the volume of suspicious transactions involving virtual IBANs due to the lack of a standardised data transmission format and the difficulty of identifying such accounts - especially overseas.

The CRF cannot provide reliable data on the number of incidents involving virtual IBANs because the information is received in an unsystematised form (e.g. Excel spreadsheets) and it is difficult to classify accounts as virtual. However, it is known that suspicious transaction reports are regularly received from institutions dealing with such accounts and mostly involve suspects outside the country.

CRF is also actively involved in international partnerships and campaigns to raise awareness among professionals who are legally obliged to report suspected money laundering.

Although the CSSF does not directly monitor the misuse of Luxembourg banks' brands, it regularly publishes warnings about fraud and fake websites. This practice is recognised by GAFI (Financial Action Task Force) and serves as an important element of preventive work: fake sites are referred to the prosecutor's office and information is sent through official channels.