Administrative sanction of 11 September 2025
Executive Summary
The CSSF imposed a €10,000 administrative fine on Lion Management, an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the 4 April 2025 deadline. This enforcement action demonstrates the CSSF's commitment to enforcing cooperation obligations under Luxembourg's anti-money laundering and terrorist financing framework, with direct implications for all AIFMs regarding timely compliance with supervisory reporting requirements.
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 AM
What You Need To Do
- *Establish Calendar Controls
- *Designate Responsible Parties
- *Monitor CSSF Communications
- *Document Submission
- *Escalate Non-Compliance Immediately
- *Review Related Obligations
Key Dates
Compliance Impact
Urgency: HIGH
Who is Affected
Summary
Administrative sanction imposed on the alternative investment fund manager Lion Management (“AIFM”)