Against a backdrop of constantly evolving restrictive measures in Europe and around the world, a law creating a monitoring committee for restrictive measures in financial matters (the “Law”) was published in the Luxembourg official gazette on 22 July 2022.

Not only does the Law establish a committee tasked with monitoring the implementation of restrictive measures in financial matters, but it also expands the list of primary offences in the fight against money laundering and terrorist financing.

As from 24 July 2022, improper implementation of restrictive measures in financial matters or of enforcement measures and decisions referred to in the law of 19 December 2020 is viewed as facilitating the misleading justification of the origin of direct or indirect income of perpetrators of offences.

Therefore, non-compliance in implementing restrictive financial measures, enforcement measures or decisions is now a primary offence which may give rise to money laundering as defined under Article 506-1 of the Criminal Code.

To read the new Law, click here_

If you require more information on the anti-money laundering and counter-terrorist financing regime, do not hesitate to contact us.