Verifying who is really behind a Luxembourg company is complicated. International tools like Onfido or ComplyAdvantage know how to scan an ID card and check sanctions lists. But they stop there. When the investor goes through a cascade of holding companies, fund associations, foreign trusts and nominees, your international tools return an "OK" score and the regulator still asks how you identified the real beneficial owner. Our KYC Luxembourg is built for that work. Reconstruction of complex organisation charts down to natural persons, integration of Luxembourg registers, explainable scoring, and an AI agent that digs when standard sources return nothing.
For an individual: identity + patrimonial situation + source of funds + liveness selfie + eIDAS qualified e-signature via LuxTrust or Itsme. For a company: enter RCS number, automatically retrieve directors, agents, shareholders, articles, K-bis. Each UBO becomes an individual personal journey. Client doesn't wait 3 weeks: full KYC often within 24 hours.
This is the Luxembourg core business. The tool climbs each ownership branch, level by level, multiplying percentages, until identifying natural-person beneficial owners under the 13 January 2019 law. It handles SOPARFI, SCS, SCSp, SCA, SA, SARL, RAIF, SIF, SICAV, SICAR, foundations, ASBL, foreign trusts, nominee shareholders. It compares what it reconstructs with the RBE declaration filed by the entity and flags divergences. Interactive graphical visualisation with auditable PDF export.
The tool continuously scans your portfolio against UN, EU consolidated, OFAC SDN, UK HMT, national sanctions lists. It identifies politically exposed persons, their family, their associates. It aggregates adverse media mentions. But mostly, it intelligently filters false positives: multilingual phonetic matching (Arabic, Cyrillic, Chinese), date of birth / country / profession cross-checking, learning from past analyst decisions. No more drowning in useless alerts.
When the CSSF asks why a client is rated 67/100, you need to answer. Our scoring aggregates 8 weighted dimensions (country, structure, sector, PEP, sanctions, adverse media, behavioural, onboarding channel) with an explainable model (documented gradient boosting, not an opaque neural network). Each score is broken down dimension by dimension with quantified contribution of each factor. You justify every decision to the auditor in 2 minutes.
The feature that changes everything on complex cases. An indirect UBO via a Cayman trust, an individual with no digital footprint to verify PEP status, an RBE declaration inconsistent with the economic context: your standard KYC returns "OK" and you know that's not enough. You launch the AI agent. It receives the question, develops an investigation plan, searches the web with advanced operators, reads UK Companies House annual returns, cross-checks with OpenSanctions, OCCRP Aleph, ICIJ Offshore Leaks (Pandora Papers, Panama Papers), Luxembourg local press (Paperjam, Delano, Wort). It returns an argued dossier with cited sources. You validate or reject.
The tool exactly reflects the responsibility structure CSSF Regulation 12-02 imposes: front office initiates, RC validates, RR escalates if needed, authorised manager decides critical cases. Predefined workflows for standard onboarding, EDD, enhanced due diligence, sanctions alert (automatic temporary freeze), periodic review per risk class, and suspicious transaction report to the Financial Intelligence Unit via goAML with pre-drafted argued narrative validated by human.
For banking or insurance secrecy actors (Article 41 LSF), no covered data leaves your infrastructure. The AI engine routes each task by sensitivity: documentary OCR in specialised cloud for non-sensitive documents, AI model installed on your own server (vLLM, Ollama, local Mistral) for analysis of contracts under secrecy. That's what lets banks and PSFs use an AI agent without CSSF exception.
For each client: complete dossier exportable as digitally signed PDF with documents, decisions, scores, alerts, investigation files. For management: quarterly dashboard structured per CSSF expectations. For RR: automatic annual AML report. For FIU: pre-filled goAML format suspicious transaction reports. For external auditor: read-only access with timestamped signed export. Immutable audit trail (cryptographic signatures, eIDAS qualified timestamping), 5-year retention post-relationship per AML law.
Retail banks, private banks, business banks Luxembourg: individual and institutional client onboarding, periodic KYC renewed every 1-3 years per risk.
PSFs (specialised, support, others) supervised by CSSF: institutional client KYC, counterparty KYC.
Management companies (UCITS, AIFM, ManCo) and funds (SIF, SICAV, SICAR, RAIF): individual and corporate subscriber onboarding, final UBO identification, distributor due diligence.
Trustees, family offices: KYC of settlors and beneficiaries of structures they administer.
Life insurance (CAA): KYC of subscribers and designated beneficiaries.
Crypto-asset platforms (CASPs) under MiCA: mandatory KYC since December 2024.
Law firms and accountants under Luxembourg AML law.
Module integrated with LuxGap platform (shared with DPO Assistant and Third Party Register): a KYC client can become a vendor in TPR without re-entry, a KYC document enters DPO Assistant's erasure scope at end of AML period. Integrable IDV providers: Onfido, Sumsub, Veriff, Fourthline, ComplyCube, Didit (EU sovereign positioning). Screening databases: Dow Jones, LSEG World-Check, LexisNexis, ComplyAdvantage, Sanction Scanner. Core banking connectors: Avaloq, Temenos T24, Olympic. Luxembourg hosting, 100% on-premise mode for Article 41 LSF secrecy.
POC with no long-term commitment. Tailored quote within one business day.
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