Published on 16 November 2025
Publication of the results of the thematic review concerning measures implemented by Luxembourg investment fund managers to combat the proliferation financing risk
CSSF
In 2024, the AML/CFT division of the UCI On-site Inspections department conducted a thematic review on five Luxembourg-based investment fund managers, which focused on the IFMs’ potential exposure to the risks related to the financing of proliferation of weapons of mass destruction (hereafter “WMD”) at asset level, in particular with regard to dual-use goods (hereafter “DUGs”) and investments in vessels, shipping or other transportation means.
During its review, the CSSF established that the sampled IFMs were aware of and prepared for the topic, even if the measures that they implemented to combat the proliferation financing risk were still maturing. This is in line with the proliferation financing risk identified for the Luxembourg fund industry, which is estimated to be low
The rationale, context and results of the thematic reviews are available below.
https://www.cssf.lu/wp-content/uploads/Counter-Proliferation-Financing-Thematic-Review.pdf