6 counterfeit goods SARs NOT FILED & multiple other AML failures result in a €214,000 fine
09/09/2025
Luxembourg’s financial regulator, the Commission de Surveillance du Secteur Financier (CSSF), has imposed a €214,000 fine on Alipay (Europe) Limited S.A. for significant breaches of anti-money laundering (AML), counter-terrorist financing (CFT), and sanctions compliance obligations.
Key Findings from the CSSF Inspection (June 2023 – January 2024):
- Failure to Report Suspicious Transactions
- Alipay failed to report six suspicious transactions related to counterfeit goods.
- Three of these involved closed accounts, yet no notification was made to the Financial Intelligence Unit (FIU), violating Article 5(1) of the AML/CFT Law.
- Inadequate Investigations
- Alipay failed to investigate red flags such as discrepancies in merchant profiles and irregular pricing of branded goods, violating obligations to scrutinise unusual transactions.
- Delayed Alert Handling
- Alerts generated by transaction monitoring were processed too slowly, undermining the ability to respond to potential money laundering or terrorist financing.
- This delay also meant Alipay couldn’t apply restrictive financial measures promptly when needed.
- Sanctions Compliance Failures
- Alerts related to financial sanctions were closed with delays, breaching Article 3(2)(d) of the AML/CFT Law and CSSF Regulation 12-02.
- Customer Due Diligence (CDD) Deficiencies
- Missing identification documents for clients and beneficial owners.
- No enhanced safeguards for non-face-to-face relationships, despite known risks of fake KYC documentation.
- Deficient Blocking Process
- Transactions occurred on accounts flagged for suspicion or incomplete KYC, indicating poor follow-up and inadequate blocking mechanisms.
- Outsourcing Oversight Failures
- Compliance monitoring of outsourced functions was too generic and lacked defined controls or KPIs.
- The second line of defence did not perform regular checks on third-party obligations.
CSSF’s Response
- The CSSF acknowledged that Alipay had cooperated fully, accepted the findings, and implemented corrective measures following the inspection.
References
LATEST: Chinese payments giant Alipay fined in Luxembourg for ...https://www.amlintelligence.com/2025/09/latest-chinese-payments-giant-alipay-fined-in-luxembourg-for-important-aml-breaches/
Administrative sanction - CSSF.lu https://www.cssf.lu/wp-content/uploads/S_2_EME_Alipay-Europe-Limited-S.A._190525_en.pdf
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.