Administrative sanction of 11 September 2025

What Changed

• This is not a regulatory change but rather an enforcement action clarifying existing obligations. However, it reinforces critical compliance requirements:
• Mandatory Annual Questionnaire Submission: All CSSF-supervised professionals, including AIFMs, must submit an annual questionnaire on financial crime by the specified deadline (in this case, 4 April 2025 for the year ending 31 December 2024).
• Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on the fight against money laundering and terrorist financing establishes a non-negotiable obligation to cooperate with the CSSF.
• Enforcement Escalation: The CSSF will issue reminders before imposing sanctions, but failure to respond to reminders results in administrative fines determined under Article 8-4 of the AML/CFT Law.

Suggested Considerations

• *Establish Calendar Controls: Implement firm-wide systems to track the annual financial crime questionnaire deadline (typically 4 April for the prior calendar year)
• *Designate Responsible Parties: Assign clear ownership for questionnaire completion and submission to the CSSF, with escalation procedures
• *Monitor CSSF Communications: Establish protocols to immediately flag and respond to any CSSF correspondence, including reminders or requests for information
• *Document Submission: Maintain evidence of timely submission (timestamps, confirmation receipts) to demonstrate compliance
• *Escalate Non-Compliance Immediately: If submission cannot be met by deadline, proactively contact the CSSF to explain delays and request extensions rather than ignoring reminders
• *Review Related Obligations: Given CSSF Circular 25/894, ensure notification requirements for non-authorised funds are also tracked and met within specified timeframes

Key Dates

Who is Affected