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 CSSF-supervised professionals must submit an annual questionnaire on financial crime covering the preceding calendar year.
• Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT imposes a non-negotiable duty to cooperate with CSSF supervisory requests.
• Enforcement Escalation: The CSSF will issue reminders before imposing sanctions, but continued non-compliance triggers administrative fines under Article 8-4 of the AML/CFT Law.

Suggested Considerations

• regulated entities must:
• *Identify Reporting Obligations: Confirm whether your firm is subject to the annual financial crime questionnaire requirement under Article 5(1) of the AML/CFT Law
• *Calendar Management: Establish internal processes to ensure questionnaires are submitted by 4 April each year for the preceding calendar year
• *Documentation: Maintain records demonstrating timely submission and preserve evidence of compliance
• *Escalation Protocol: If unable to meet deadlines, proactively contact the CSSF to request extensions or clarification rather than ignoring reminders
• *Governance: Assign clear responsibility for AML/CFT questionnaire completion at the board or senior management level

Key Dates

Who is Affected