Administrative sanction of 11 September 2025

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.

Suggested Considerations

• *Establish Reporting Calendars: Implement systems to track the 4 April annual deadline for financial crime questionnaire submissions
• *Designate Responsible Personnel: Assign clear accountability for completing and submitting the questionnaire to the CSSF
• *Respond to Regulatory Requests: Do not ignore CSSF reminders; engage proactively, including requesting in-person meetings if clarification is needed
• *Document Justifications: If unable to meet deadlines, provide written evidence explaining the delay and proposed remediation timeline
• *Monitor Supervisory Communications: Establish procedures to ensure regulatory correspondence is tracked and escalated appropriately

Key Dates

Who is Affected