Administrative sanction of 11 September 2025
Executive Summary
The Commission de Surveillance du Secteur Financier (CSSF), Luxembourg's financial regulator, imposed a **EUR 10,000 administrative fine on Agriland Management S.A.**, an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's commitment to enforcing cooperation obligations under Luxembourg's anti-money laundering and terrorist financing (AML/CFT) framework and signals heightened scrutiny of compliance with supervisory reporting requirements.
What Changed
This is not a regulatory change but rather an enforcement action that clarifies existing obligations: - Mandatory Annual Reporting: All CSSF-supervised professionals must submit an annual questionnaire on financial crime by 4 April each year, covering the preceding calendar year. - Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, including timely submission of requested documentation. - Enforcement Escalation: The CSSF will issue reminders for non-compliance, but continued failure to respond triggers administrative sanctions without requiring evidence of intentional misconduct.
What You Need To Do
- *Establish Reporting Calendars
- *Designate Responsible Personnel
- *Respond to Regulatory Requests
- *Document Justifications
- *Monitor Supervisory Communications
Key Dates
Compliance Impact
Urgency: HIGH
Who is Affected
Summary
Administrative sanction imposed on the alternative investment fund manager Agriland Management S.A. (“AIFM”)