ARTICLE
9 September 2026

CSSF Imposes Fine For AML And Sanctions Compliance Violations

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Duane Morris LLP

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Luxembourg's CSSF imposed a €56,000 fine on Stonehage Fleming Luxembourg S.A. for multiple compliance failures, including significant delays in processing sanctions screening alerts and implementing changes to screening lists. At the time of inspection, hundreds of alerts had been treated with substantial delays and 42 alerts remained completely unnoticed by the financial services provider.
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In an Administrative Sanction published by Luxembourg’s CSSF, a fine of €56,000 was imposed on Stonehage Fleming Luxembourg S.A.

Most of the notice relates to AML compliance failings, but included was a complaint as regards to the resolution of sanctions screening hits and a delay in implementing changes to lists for screening purposes:

At the time of the on-site inspection, hundreds of name screening alerts had been treated with significant delays and 42 alerts remained unnoticed by the PFS. These delays constitute a breach of the obligations foreseen in Article 3(2) point (d) of the AML/CFT Law and in Article 33(1) of CSSF Regulation No 12-02, as the PFS was unable to identify “without delay” persons subject to restrictive measures in financial matters and therefore apply “without delay” potential restrictive measures in financial matters as the case may be“.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.

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