Global sanctions guide

  1. Does Luxembourg have a sanctions regime in place?

Yes. International financial sanctions apply to any Luxembourg natural or legal person, as well as any other natural or legal person operating in or from Luxembourg.

  1. Does Luxembourg implement UN sanctions?

Yes. Luxembourg is a member of the European Union, which implements UN sanctions in all member states by way of directly applicable regulations. As well, Luxembourg has implemented UN sanctions in relation to Al Qaeda and the Taliban/Afghanistan.

  1. Does Luxembourg implement an autonomous sanctions regime?

Yes. Luxembourg has an autonomous sanctions regime in relation to terrorist financing, pursuant to the Law of 27 October 2010 implementing UN Security Council resolutions as well as acts adopted by the EU concerning prohibitions and restrictive measures in financial matters in respect of certain persons, entities and groups (the “Law”). Furthermore, the Commission de Surveillance du Secteur Financier (“CSSF”) implements its own regulations which apply to Luxembourg’s financial sector.

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

Luxembourg follows the restrictive measures laid down by the UN, the EU and other international organisations which are binding on Luxembourg. Luxembourg’s autonomous measures centre around international financial sanctions in the context of money laundering and terrorist financing.  Sanctions 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
  1. Does Luxembourg maintain a list of sanctioned individuals and entities?

Yes. The Grand-ducal Regulation of 29 October 2010 lists the natural and legal persons, entities or groups who are subject to sanctions and prohibitions. As well, the CSSF and the Ministry of Finance’s websites contain links to a consolidated list of individuals and entities subject to EU financial sanctions.

  1. Are there any other lists related to sanctions?

Yes. The CSSF’s website also contains links to lists of persons and entities connected to both Al Qaeda and the Taliban/Afghanistan.

  1. Does Luxembourg have a licensing or authorisation system in place?

Yes. The Minister of Finance is authorised to deal with questions and challenges regarding the implementation of sanctions and restrictive measures.

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

The consequences for a breach of sanctions are a fine of between €251 and €250,000 and/or imprisonment between 8 days and 5 years. These consequences are without prejudice to more severe penalties which may be available under other provisions relating to the conduct which caused the breach.

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

The Minister of Finance is responsible for overseeing sanctions and restrictive measures in Luxembourg.

Ministry of Finance
3 Rue de la Congrégation
L-1352 Luxembourg

T: (+352) 247 82600
F: (+352) 475 241 (French language only)

The CSSF is responsible for restrictive measures in Luxembourg’s financial sector.

Commission de Surveillance du Secteur Financier
110 Route d’Arlon
L-1150 Luxembourg

T: (+352) 26 25 1 – 1
F: (+352) 26 25 1 – 2601

The Minister of Foreign Affairs is the competent authority for informing the United Nations of persons and entities caught by UNSC Resolution 1267/1999 (as amended) (relating to Afghanistan), so that they may be added to the UN’s consolidated list.

Minister of Foreign Affairs
5 Rue Notre-Dame
L-2240 Luxembourg

T: (+352) 247 82300
F: (+352) 223 144
E: (French language only)

Contributor law firm

Audrey Risser, Bonn Steichen & Partners, 2, rue Peternelchen - Immeuble C2, L-2370 Howald, Luxembourg

T: (+352) 26 025 1
F: (+352) 26 025 999