1. Does Luxembourg have a sanctions regime in place?

Yes. International financial sanctions are imposed on any Luxembourg natural or legal person, as well as on any other natural or legal person operating in or from the Luxembourg territory.

2. Does Luxembourg implement UN sanctions?

Luxembourg is a member of the European Union, which implements sanctions adopted by the UN Security Council in all Member States by way of directly effective EU legislation.

3. Does Luxembourg implement an autonomous sanctions regime?

Yes, by the law of October 27, 2010 relating to the implementation of UNSC resolutions as well as acts adopted by the EU concerning prohibitions and restrictive measures in financial matters in respect of certain people, entities and groups in the context of the combat against terrorist financing (the “Law”). Furthermore, the Commission de Surveillance du Secteur Financier (“CSSF”) implements its own Regulations applicable to Luxembourg’s financial sector.

4. What is the nature of the sanctions regime in Luxembourg?

The sanctions regime in Luxembourg centers around international financial sanctions within the context of the fight against money laundering and terrorist financing. The sanctions with regard to natural or legal persons, entities or groups concerned include:

  • the prohibition or restriction of financial activities of any type
  • the seizure of movable and immovable property, the freezing of funds, assets or other economic resources held or controlled, directly, indirectly or jointly, with or by a person, entity or group mentioned by the law or by a person acting on behalf of them or according to their instructions
  • the prohibition or restriction on providing financial services, technical training or consulting assistance to a person, entity or group referred to by the law

5. Does Luxembourg maintain a list of sanctioned individuals and entities?

The Grand-ducal regulation of 29 October 2010 enforcing the Law designates the natural and legal people, entities or groups who are subjected to the measures and prohibitions. It consists namely of European regulations, directly applicable, and the implementation, through ministerial regulations, of certain UN sanctions lists. The CSSF and the Minister of Finance websites contain a link to a consolidated list of individuals and entities subject to EU financial sanctions.

6. Are there any other lists related to sanctions?


7. Does Luxembourg have a licensing or authorization system in place?

Yes, an authorization or a license can be required for some financial activities.

The Minister of Finance is competent to deal with any questions and challenges regarding the implementation of the prohibitions and restrictive measures. Furthermore, he is competent to exceptionally issue authorisations derogating from the prohibitions and restrictive measures imposed, insofar as United Nations resolutions and European Union acts permit this and under the conditions laid down therein.

In addition, l’Office du contrôle des exportations, importations et du transit (the Office of Export, Import and Transit Control) within the Ministry of Economy is the competent authority for issuing authorizations for the export, transfer, transit and import of goods of a strictly civil nature, of defense-related products and dual-use goods, brokering and intangible transfers of technology of such products and implements the restrictive measures enacted by the European Union in the field of trade in such goods against certain states, political regimes, persons, entities and groups.

8. What are the consequences for a breach of sanctions in Luxembourg?

The Law provides that without prejudice to the application of more severe penalties that may be provided for under other legal provisions, violations of the Law and its implementing regulations shall be punished by a prison term of between eight days and five years and a fine of between EUR 251 and EUR 250,000, or by one of these penalties to the exclusion of the other.

Where the offence resulted in significant financial gain, the fine may be increased to four times the amount of the offence.

9. Who are the relevant regulators in Luxembourg and what are their contact details?

Ministry of Finance 3 Rue de la Congrégation L-1352 Luxembourg T: (+352) 247 82600

The Minister of Finance is competent to deal with all matters relating to the implementation of financial sanctions both on the part of those targeted by these measures and on the part of those obliged to apply them.

CSSF 283, route d’Arlon, L-1150 Luxembourg T: (+352) 26 25 1 – 1 The Commission de Surveillance du Secteur Financier performs its duties of prudential supervision and supervision of the markets for the purposes of ensuring the safety and soundness of the financial sector, solely in the public interest. Within the limits of its remit, it ensures that the authorised entities and the issuers are complying with the regulations applicable to them, including those aiming to ensure the protection of the financial consumers and the prevention of the use of the financial sector for the purposes of money laundering or terrorist financing.

Minister of Foreign Affairs 9 Rue du Palais L-1841 Luxembourg T: (+352) 24 78 40 40

The Ministry of Foreign Affairs, and more specifically the Directorate for International Economic Relations, is responsible for the general coordination of economic and financial restrictive measures decided by the United Nations Security Council and the European Union (EU). They work together with the other national institutions responsible for the implementation of the restrictive measures within the framework of inter-ministerial committees.

Cellule de renseignement financier (CRF)

Bureaux : 41B, bd. Franklin D. Roosevelt L-2450 Luxembourg T: (+352) 47 59 81-2447

The mission of the Cellule de renseignement financier (Financial Intelligence Unit) is to receive and analyse suspicious transaction reports and other information concerning suspicious facts that may relate to money laundering, related predicate offences or terrorist financing.

Ministère de l’Economie – Office du contrôle des exportations, importations et du transit (OCEIT) 19-21 Boulevard Royal L-2449 Luxembourg T: (+352) 22 61 62 L’Office du contrôle des exportations, importations et du transit is a service operating under the authority of the Ministry of the Economy. This office is in charge, among others, of the application of the regime governing the import, export, intra-Community transfer and transit of certain types of goods whose trade is regulated.

Contributor law firm

Anne Morel, Partner

Harmonie MÉRAUD, Senior Associate

Bonn Steichen & Partners

2, rue Peternelchen - Immeuble C2

L-2370 Howald


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