Luxembourg Fines Financial Firm for Terrorist Financing Law Violations

Luxembourg's Commission de Surveillance du Secteur Financier (CSSF) announced this week that it imposed an over $44,600 fine on Dock Financial, an "electronic money institution," for skirting money laundering and terrorist financing obligations. CSSF identified the company's violations during an on-site inspection from 2021 to 2022, finding that a "substantial part" of Dock's client portfolio wasn't subject to the required name screening controls "on a daily basis, over a substantial period of time." The commission also said, although Dock identified suspicions of money laundering "in 11 client files," the company reported them "with substantial delays." CSSF faulted the company's "internal governance framework," finding it deficient due to "insufficient controls performed by the second and the third lines of defence."