Administrative sanction of 11 September 2025
Executive Summary
The CSSF imposed a **€10,000 administrative fine on Sunbricks GP S.à r.l.**, an alternative investment fund manager, for failing to submit a mandatory annual financial crime questionnaire by the April 4, 2025 deadline, despite two formal reminders. This enforcement action demonstrates the CSSF's strict approach to cooperation obligations under Luxembourg's anti-money laundering and counter-terrorist financing (AML/CFT) framework and signals that non-submission of required compliance documentation—even without evidence of underlying financial crime—triggers regulatory penalties.
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.
What You Need To Do
- regulated entities must
- *Establish Calendar Controls
- *Designate Responsible Parties
- *Prepare Documentation
- *Monitor Communications
- *Request Extensions Proactively
Key Dates
Compliance Impact
Urgency: HIGH
Who is Affected
Summary
Administrative sanction imposed on the alternative investment fund manager Sunbricks GP S.à r.l. (“AIFM”)