Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 718 cases from 32 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

3cases from 1 jurisdiction
€3.09mTotal of monetary amounts
€1.68mLargest single case: Lombard International Assurance S.A.
€790,000Median per case with an amount

Click a bar to drill down one level.

Where?

by authority
  1. Commissariat aux Assurances (CAA) €3.09m 100 % · 3 cases

What for?

by topic
  1. Internal controls €2.47m 80 % · 2 cases
  2. Customer due diligence €615,000 20 % · 1 case

Who?

by sector

All sectors

  1. Financial services and insurance €3.09m 100 % · 3 cases

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20230—
Q4 20231€790,000
Q1 20241€1.68m
Q2 20240—
Q3 20240—
Q4 20240—
Q1 20250—
Q2 20250—
Q3 20250—
Q4 20250—
Q1 20261€615,000
Q2 20260—
Q3 20260—

3 cases

20 Jan 2026 Cardif Lux Vie S.A.Cardif Lux Vie: 615,000 EUR over deficiencies in money laundering questionnaires and customer files LuxembourgCustomer due diligence €615,000

An on-site inspection in 2023 revealed that the life insurer in some cases did not handle the mandatory money laundering risk assessment questionnaires in compliance with the rules, that the employees responsible lacked sufficiently precise instructions and that customer files contained many incorrect answers. The Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) imposed 615,000 EUR.

What organisations can take from it

Risk questionnaires are only as good as the guidance given to those who complete them – clear work instructions and training are part of this.

Relevance to training and awareness

Money laundering risk assessment by employees

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Loi modifiée du 12 novembre 2004 (LBC/FT), Art. 2-1, 8-4, 8-5; Règlement CAA 20/03
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Close cooperation with the CAA during and after the inspection; remediation plan for all deficiencies submitted promptly.
Published
1 Jul 2026

Checked against the official source on 25 Sep 2026 · Direct link

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10 Jan 2024 Lombard International Assurance S.A.Lombard International Assurance: 1.68 million EUR over missing overall money laundering risk assessment LuxembourgInternal controls €1.68m

During an inspection in 2021/2022, the Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) found that the life insurer had not prepared an overall assessment of its money laundering risks, that guidance for employees on due diligence obligations (beneficial owners, high-risk countries, PEPs) was inadequate and that it was not checked whether the intermediaries used fulfilled their due diligence obligations. It imposed 1,682,000 EUR.

What organisations can take from it

Without a documented overall risk assessment, a risk-based approach cannot be demonstrated – intermediaries must also be monitored.

Relevance to training and awareness

Due diligence obligations regarding beneficial owners and PEPs

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Loi modifiée du 12 novembre 2004 (LBC/FT), Art. 2-1, 2-2, 8-4, 8-5; Règlement CAA 20/03
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
20 Mar 2024

Checked against the official source on 25 Sep 2026 · Direct link

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16 Oct 2023 Swiss Life (Luxembourg)Swiss Life (Luxembourg): 790,000 EUR over deficiencies in anti-money laundering LuxembourgInternal controls €790,000

An inspection in 2021 revealed that the life insurer had not carried out an overall assessment of its money laundering risks and that the guidance for employees on due diligence obligations (beneficial owners, high-risk countries, PEPs) was inadequate. The Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) imposed 790,000 EUR.

What organisations can take from it

The overall money laundering risk assessment is the basis of all due diligence obligations and must be in place before new business relationships are entered into.

Relevance to training and awareness

Customer due diligence in insurance distribution

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Loi modifiée du 12 novembre 2004 (LBC/FT), Art. 2-1, 2-2, 8-4, 8-5; Règlement CAA 20/03
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
3 Jul 2024

Checked against the official source on 25 Sep 2026 · Direct link

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