DiscoverCompliance Officers PlaybookFreemium - The Cost of Postponing Compliance: CSSF fines AllianzGI Luxembourg for AML/CFT failures
Freemium - The Cost of Postponing Compliance: CSSF fines AllianzGI Luxembourg for AML/CFT failures

Freemium - The Cost of Postponing Compliance: CSSF fines AllianzGI Luxembourg for AML/CFT failures

Update: 2025-11-26
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In this episode, we examine the story behind a major regulatory enforcement action in Luxembourg’s financial sector: the €283,000 administrative fine imposed on Allianz Global Investors’ Luxembourg branch for persistent anti-money laundering (AML) and counter-terrorist financing (CFT) failures.

We unpack the findings of a 2018 CSSF inspection that uncovered serious gaps—including the omission of more than 1,000 investors from the branch’s AML/CFT risk analysis and weak due-diligence documentation for politically exposed persons (PEPs). Although AllianzGI maintains that the issues were procedural and have since been fully corrected, the case highlights a broader industry trend in which firms delay critical compliance work to focus on short-term business priorities.

We also discuss the timeline: the penalty issued in 2022 and upheld in court in 2025—evidence of the regulator’s determination to confront systemic weaknesses in financial controls.

Tune in for a clear look at what this case means for compliance culture, supervisory expectations, and the financial industry’s ongoing struggle to balance growth with robust risk management.

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Freemium - The Cost of Postponing Compliance: CSSF fines AllianzGI Luxembourg for AML/CFT failures

Freemium - The Cost of Postponing Compliance: CSSF fines AllianzGI Luxembourg for AML/CFT failures

Compliance Officers Playbook