Administrative sanction of 11 September 2025

What Changed

• This is not a regulatory change but rather an enforcement action clarifying existing obligations:
• Mandatory Annual Questionnaire Requirement: All professionals supervised, authorized, or registered by the CSSF must submit an annual questionnaire on financial crime by April 4 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, which includes timely submission of requested documentation.
• Administrative Fine Framework: The CSSF applies Article 8-4 of the AML/CFT Law to impose fines for non-compliance, with amounts determined under Article 8-5 based on all relevant circumstances.

Suggested Considerations

• regulated entities must:
• *Establish Calendar Controls: Implement internal compliance calendars flagging the April 4 annual questionnaire submission deadline with sufficient lead time (minimum 4-6 weeks before deadline)
• *Designate Responsible Parties: Assign clear ownership for questionnaire completion and submission, with backup contacts
• *Prepare Documentation: Maintain contemporaneous records of financial crime controls, suspicious activity reporting, and compliance activities throughout the year to support accurate questionnaire responses
• *Monitor Communications: Ensure all CSSF correspondence is tracked and escalated immediately; do not ignore reminder notices
• *Request Extensions Proactively: If submission will be delayed, request an in-person meeting with the CSSF to discuss circumstances and seek relief (the enforcement decision notes that Sunbricks GP neither requested such a meeting nor provided justification)

Key Dates

Who is Affected