Administrative sanction of 11 September 2025
AI Analysis
The CSSF imposed a €10,000 administrative fine on Max Gain Capital S.à r.l., an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's active monitoring of AML/CFT compliance obligations and its willingness to sanction non-cooperation, even for procedural failures unrelated to substantive money laundering violations.
Key dates
- 4 April 2025 Deadline
- - Deadline for submission of financial crime questionnaire for the year ending 31 December 2024
- Before 11 September 2025 Deadline
- - CSSF issued two reminders to Max Gain Capital after the missed deadline
- 11 September 2025
- - CSSF imposed the €10,000 administrative fine
- 9 January 2026
- - CSSF published the administrative sanction decision
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
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.
Compliance impact
Urgency: HIGH
Who is affected
References
AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.
What the CSSF said
Administrative sanction imposed on the alternative investment fund manager Max Gain Capital S.à r.l. (“AIFM”)
Published by CSSF . Read the full notice at the source for the authoritative text.