Publication of the update of the ML/FT Sub-Sector Risk Assessment on Specialised Professionals of the Financial Sector providing corporate services (trust and company service provider activities)

With assistance from the members of the Public-Private Partnership regarding specialised professionals of the financial sector (PPP PSF-SP), which includes representatives of ALCO, L3A, LPEA, LAFO, ALRiM, the FIU and the CSSF, the CSSF has updated its Sub-Sector Risk Assessment on Specialised Professionals of the Financial sector providing corporate services (SSRA TCSP) of 2020.

Since the publication of the first SSRA TCSP, Luxembourg has made several important publications relating to AML/CFT. A Vertical Risk Assessment on Legal Persons and Legal Arrangements and a Vertical Risk Assessment on Terrorist Financing were published in 2022. Furthermore, a revised National Risk Assessment of Money Laundering was published in 2025.

Drawing on the experience gained from these assessments, as well as the FATF Mutual Evaluation Report of 2023, the CSSF has now reviewed and updated the SSRA TCSP. The 2026 SSRA TCSP update includes several new sections and appendixes (e.g. on terrorist financing risks, proliferation financing risks, new or developing risks, as well as high level summaries on banks and investment firms performing TCSP activities) and provides updated recommendations to Specialised Professionals of the Financial Sector.

The CSSF expects all supervised entities providing corporate services activities (Trust and Company Service Provider activities) to integrate the findings, conclusions and recommendations resulting from this sub-sector risk assessment into their AML/CFT frameworks to ensure they remain appropriate to effectively mitigate ML/FT risks.