Luxembourg AML Law of 12 November 2004 in English
The amended Law of 12 November 2004 on the fight against money laundering and terrorist financing, as consolidated on 8 August 2026: who must apply KYC, what due diligence means in Luxembourg, how suspicious transactions are reported and what the sanctions are. Full English translation with the official French under every paragraph.
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- Official title
- Loi modifiée du 12 novembre 2004 relative à la lutte contre le blanchiment et contre le financement du terrorisme
- In English
- Law of 12 November 2004 on the fight against money laundering and terrorist financing, as amended (the “AML Law”)
- Published
- Mémorial A n° 183 of 19 November 2004; in force 23 November 2004
- Version translated
- Consolidated text applicable from 8 August 2026, as last amended by the Laws of 16 July 2026 and 22 July 2026
- EU basis
- Directive (EU) 2015/849 (Fourth Anti-Money Laundering Directive), as amended by Directive (EU) 2018/843; Regulation (EU) 2023/1113 on transfers of funds and crypto-assets
- Supervisors
- CSSF, Commissariat aux Assurances, AED, and the self-regulatory bodies of lawyers, notaries, auditors, accountants and bailiffs
- Authentic language
- French
- Official source
- legilux.public.lu
The text in 4 parts
Money laundering and terrorist financing, the beneficial owner and PEP definitions, the list of professionals covered, and which authority or self-regulatory body supervises each. 3 articles.
Arts. 2-2 to 7-2Risk assessment, customer due diligence and reportingRisk assessment, standard, simplified and enhanced due diligence, reliance on third parties, internal organisation and group policies, reporting to the FIU, and rules for lawyers and trust and company service providers. 13 articles.
Arts. 8-1 to 9Supervision, administrative sanctions and criminal finesPowers of the CSSF, the CAA, the AED and the self-regulatory bodies, whistleblowing, the administrative sanctions and their publication, and criminal fines. 16 articles.
Arts. 9-1 to 25 and AnnexesCooperation, appeals, transitional provisions and annexesNational and international cooperation, the AML/CFT prevention committee, appeals against FIU instructions, transitional provisions for virtual asset service providers, and the annexed risk-factor lists. 18 articles.
In short
- The beneficial owner is the natural person who ultimately owns or controls the customer; holding more than 25% of the shares or ownership interest is an indication of ownership. If no one qualifies, the senior managing officials are named (Art. 1). This is the definition the RBE and RFT registers use.
- The Law covers banks and other financial professionals, insurers, auditors, accountants, tax advisers, lawyers and notaries for certain transactions, real estate agents, domiciliation agents, trust and company service providers, crypto-asset service providers, and dealers taking 10,000 euros or more in cash (Art. 2).
- Professionals must identify the customer and the beneficial owner, understand the purpose of the relationship and monitor it, for every business relationship and for occasional transactions from 15,000 euros (Art. 3).
- Enhanced due diligence applies to politically exposed persons, high-risk third countries, correspondent relationships and other higher-risk situations (Art. 3-2).
- Suspicions must be reported promptly to the Financial Intelligence Unit, and the customer may not be told (Art. 5).
- Administrative fines reach 5 million euros or 10% of annual turnover for legal persons (Art. 8-4); knowing breaches of the core obligations are criminal offences with fines of 12,500 to 5,000,000 euros (Art. 9).
Who it affects
- Founders and shareholders of Luxembourg companies, who meet this Law every time a bank, notary or domiciliation agent asks for documents.
- Banks, payment and e-money institutions, investment funds and their managers.
- Notaries, lawyers, auditors, accountants, tax advisers and domiciliation agents.
- Real estate agents, dealers in high-value goods and art, and crypto-asset service providers.
Key dates
| Date | Event |
|---|---|
| 12 November 2004 | Law adopted; published in Mémorial A n° 183 |
| 23 November 2004 | Law enters into force |
| 2018–2020 | Transposition of the Fourth and Fifth AML Directives: risk-based approach, beneficial owner rules, register links |
| 13 December 2024 | Law of 4 December 2024 in force: Committee for the prevention of money laundering and terrorist financing set up |
| 27 July 2026 | Law of 16 July 2026 in force: further amendments to this Law |
| 8 August 2026 | Law of 22 July 2026 in force; date of the version translated |
| 10 July 2027 | EU Anti-Money Laundering Regulation (EU) 2024/1624 applies; much of this Law will then be replaced by directly applicable EU rules |
BCA commentary
Why founders should read it
Most of what a bank or domiciliation agent asks for when you open a Luxembourg company comes from Art. 3: identity documents for the beneficial owners, the source of funds, the purpose of the structure. The Law leaves the detail to each professional’s risk assessment (Art. 2-2), which is why two banks can ask for different things.
Beneficial owner: one definition, three uses
The definition in Art. 1 feeds the professionals’ KYC, the company register of beneficial owners (RBE) and the register of fiducies and trusts (RFT). Above 25% is an indication, not a safe harbour: control by other means also counts, and where no one can be identified the senior managers are recorded instead.
Higher risk means more questions
Politically exposed persons, their family members and close associates, customers linked to high-risk third countries and complex or unusually large transactions trigger enhanced due diligence (Art. 3-2). The annexes list the factors that point to lower and higher risk (Annex 3, Annex 4).
Reporting and tipping-off
A professional who suspects money laundering must report to the FIU and may have to refrain from carrying out the transaction. The customer must not be told that a report was made (Art. 5). Lawyers are protected where they act in proceedings or give legal advice (Art. 7).
What changes in 2027
From 10 July 2027 the EU Anti-Money Laundering Regulation (EU) 2024/1624 applies directly in every Member State and takes over most of the customer due diligence rules. Expect this Law to be cut back to supervision, sanctions and the national points the Regulation leaves open.
Amendment history
Amending acts marked in the Legilux consolidation, with the articles they touch. Legilux marks only some recent changes in this Law, so this list is incomplete.
| Act | Articles |
|---|---|
| Law of 16 July 2026 | Arts. 9-1quater, 9-1sexies |
| Law of 22 July 2026 | Art. 5-1 |
Related acts
The company UBO register built on this Law’s beneficial owner definition. Translated in full.
Luxembourg · TrustsRegister of Fiducies and Trusts Law (2020)The register for fiducies and express trusts. Translated in full.
Luxembourg · RegistersLaw of 19 December 2002 on the RCSTrade and Companies Register and annual accounts. Translated in full.
EU · DirectiveDirective (EU) 2015/849Fourth Anti-Money Laundering Directive. EUR-Lex.
BCA EU · GuideBeneficial ownership in Luxembourg and the NetherlandsWho counts as UBO, what banks ask for, how to file.
How to cite
Cite the article and paragraph and link to the paragraph anchor. For example:
Unofficial English translation by BCA EU, for information. Only the French text published in the Mémorial and the Journal officiel du Grand-Duché de Luxembourg has legal force. Article headings are editorial; title, chapter and section headings and most article headings are the law’s own. Text checked against the consolidated version applicable from 8 August 2026 on legilux.public.lu on 30 October 2026. This page is not legal or tax advice.
Opening a bank account for a Luxembourg company?
We prepare the KYC file the way Luxembourg banks and domiciliation agents expect it, from beneficial ownership charts to source-of-funds evidence.