Global sanctions guide

  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.

  1. Does Luxembourg implement UN sanctions?

Luxembourg has implemented UN sanctions in relation to Al-Qaida and associated individuals and entities and Taliban/Afghanistan and associated individuals and entities.

  1. 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.

  1. 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

  1. 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. The CSSF and the Minister of Finance websites contain a link to a consolidated list of individuals and entities subject to EU financial sanctions.

  1. Are there any other lists related to sanctions?

The CSSF website also contains links to lists of persons and entities connected to both Al-Qaida and the Taliban/Afghanistan.

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

The Minister of Finance is competent to deal with any questions and challenges regarding the implementation of the prohibitions and restrictive measures.

  1. 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.

  1. 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

283, route d’Arlon, L-1150 Luxembourg

T: (+352) 26 25 1 – 1

Furthermore, according to the Law, the Minister of Foreign Affairs is designated as the competent authority for informing the United Nations Committee established by Resolution 1267 (1999) of 15 October 1999, with the approval of the Minister of Finance, of the relevant natural and legal persons, entities and groups, including any related information, so that the corresponding entries may be made on the consolidated list managed by the United Nations, in accordance with paragraphs 8 et seq. of UNSC Resolution 1904 (2009).

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
9 Rue du Palais
L-1841 Luxembourg

T: (+352) 24 78 40 40

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