Administrative sanction of 11 September 2025
Executive Summary
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) Capitalis Premiere Group on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties, signaling heightened scrutiny on timely supervisory cooperation for Luxembourg-regulated entities. Compliance teams should note this as a low-value but public reminder of potential fines for administrative lapses in AML processes. #
What Changed
This is not a regulatory change or new requirement but an enforcement precedent under existing rules: non-compliance with the annual financial crime questionnaire submission, mandated by Article 5(1) of the AML/CFT Law, triggers fines per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a). The CSSF considered all relevant circumstances under Article 8-5(1) to set the €10,000 fine amount and published the sanction nominatively after proportionality assessment per Article 8-6(1), confirming no market stability risks. No broader policy shifts; it reinforces the obligation for supervised professionals (including AIFMs under Article 3(2) of the Law of 12 July 2013) to submit questionnaires annually. #
What You Need To Do
- Ensure timely submission of annual financial crime questionnaires by 4 April each year (for prior calendar year data); implement calendar reminders and escalation processes for CSSF requests
- Respond promptly to CSSF reminders or queries on AML/CFT compliance to avoid escalation to fines; document any delays with justification evidence
- No retroactive actions needed for this case, but conduct gap analysis on reporting workflows to prevent similar breaches
Key Dates
Compliance Impact
Urgency: Medium - This €10,000 fine is modest but publicly names the firm, amplifying reputational risk in Luxembourg's competitive fund domicile; it matters as a clear CSSF signal of zero tolerance for basic cooperation failures in AML, potentially foreshadowing stricter enforcement amid EU AML harmonization pressures. AIFMs face ongoing annual risk, with non-response despite reminders treated as
Who is Affected
Summary
Administrative sanction imposed on the alternative investment fund manager Capitalis Premiere Group (“AIFM”)