Luxembourg’s Financial Sector Supervisory Commission (CSSF) fined Intercorp SA €27,000 for breaches of anti-money laundering and counter-financing of terrorism (AML/CFT) obligations, the regulator on 13 March 2025. The administrative sanction, issued on 28 November 2024, followed an on-site inspection that uncovered multiple compliance failures.
The CSSF stated that the penalty reflected the gravity and duration of the violations, the limited scope of the inspection and the financial situation of Intercorp at the time. The regulator noted that Intercorp acknowledged the findings and implemented corrective measures after the inspection.
The CSSF’s investigation, conducted between 20 June 2023 and 29 November 2023, focused on Intercorp’s domiciliation and company management services. It identified significant failures in customer due diligence, risk assessment and suspicious transaction reporting.
The regulator found that Intercorp failed to gather sufficient information on the origin of client funds and, where required, did not obtain corroborating documentation. In one case, a client classified as low risk showed inconsistencies between declared personal assets and professional income. Intercorp did not clarify these discrepancies. In another instance, a high-risk business relationship involved the acquisition of shares worth several million euros by an offshore entity controlled by an individual initially resident in a high-risk country. Despite recognising the high risk, Intercorp did not seek supporting evidence on the source of funds. A third case involved a transfer of ownership between beneficial owners in a high-risk jurisdiction without proper documentation on the origin of funds.
Intercorp was also found to have delayed reporting suspicious activities to the Financial Intelligence Unit (FIU). The CSSF concluded that Intercorp only submitted reports after the regulator’s intervention. One case involved a client whose beneficial owner was linked to allegations of corruption in two separate legal proceedings. Intercorp did not investigate the claims, despite evidence that funds related to one of the cases had passed through the client’s accounts. In another instance, Intercorp’s name screening tool flagged a trust settlor convicted of aggravated tax fraud, yet no immediate action was taken.
Further breaches were found in relation to terminated business relationships. The CSSF reported that Intercorp did not file a suspicious transaction report concerning a former client, despite being aware of legal proceedings against its beneficial owner. Additionally, a declaration concerning a terminated business relationship with a business provider was submitted more than eight months late. The report was also incomplete, failing to list clients introduced by the provider for whom key information was missing.
Paperjam has contacted Intercorp for comment.