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Courses/ AML/CFT/ Module 5/ Lesson 5.1
Lesson 1 of 3 · Module 5

Not the same regime, and why that matters

Anti money laundering is calibrated to risk. Sanctions are a prohibition, and the consequences of confusing the two start with which authority you are dealing with.

3:14 Module 5. International financial sanctions AML/CFT and KYC in Luxembourg practice
The video and the full transcript of this lesson are part of the course This page is the description of the lesson: what it is about, how long it runs and every instrument it is built from. Watching it and reading it word for word need an account with access to AML/CFT and KYC in Luxembourg practice. Two lessons of this course are open to everyone with no account and no payment.
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The course30 lessons across 7 modules, each with its transcript and its sources
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SourcesOfficial legal texts linked in each lesson
  • The video of every lesson, and the word-for-word transcript beside it
  • Every claim linked to its primary source, with a source register per lesson
  • An assessment for each of the 7 modules, and an end-of-course assessment
  • A printable certificate carrying your name, the date and the content version
  • The downloadable artefacts and one page references for this course

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The narrated video runs about 1 hour 31 minutes across the 30 lessons. That is short on purpose: no filler and no reading out of the law, with the work in the transcripts, the sources, the assessments and the artefacts.

What Module 5 covers

Module 5. International financial sanctions

Why a prohibition is not calibrated to risk and which authorities sanctions put you in front of under the Law of 19 December 2020, the screening framework made explicit by Circular CSSF 25/896 and the EBA guidelines applicable since 30 December 2025, the discipline of resolving hits rather than reducing them, and what a confirmed match obliges you to do: freeze, do not make funds available, notify the Ministry of Finance, and never release on your own authority.

Sources for this lesson

Every instrument this lesson is built from, linked to its official text

Sanctions sit outside the Law of 12 November 2004. The framework is the Law of 19 December 2020, with the Grand-ducal Regulation of 14 November 2022 beneath it. The Ministry of Finance is the competent authority for execution and for exceptional authorisations, and it publishes the national designations page; under article 4(2) of the 2020 Law the United Nations designations take effect automatically by reference to the UN list.

The rest of Module 5

Module 5. International financial sanctions

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