The unfolding Caritas embezzlement scandal has exposed critical vulnerabilities in charity management and banking oversight, raising serious questions about financial safeguards and the role of Luxembourg's regulatory framework.

The shocking embezzlement case unfolding at Caritas points to a number of anomalies, not only within the charity's management, but also in the implicated banking processes. And suspicion further increases when viewing the facts against the backdrop of a press release issued by the Financial Sector Supervisory Commission (CSSF) in May 2024.

In this statement, the CSSF reminded financial institutions that charities are particularly at risk of being exposed to financial terrorism. Although no typical patterns of donations being misused for foreign projects had been detected in Luxembourg at the time, the charity sector was identified as being "very vulnerable".

Much like the Gafi expert group, the CSSF advised against disproportionate measures and said the fight against financial terrorism should be combined with the prevention of money laundering and non-profit organisations' access to credit. It recommended applying 19 indicators to detect potential risks or abuses, including difficulties in tracing the origin or destination of funds and transactions appearing without explanation.

The recommendations clearly show why many questions are currently being asked in the financial sector: namely how the Caritas transfer of €61 million to foreign bank accounts, which took place across more than a hundred instalments over a five-month period, could happen or how additional credit lines were granted.

The CSSF is currently carrying out an analysis of what occurred at the Spuerkeess and the BGL BNP Paribas banks, both implicated in the Caritas embezzlement scandal.