Administrative sanction of 11 September 2025
Executive Summary
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.
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.
What You Need To Do
- regulated entities must
- *Identify Reporting Obligations
- *Calendar Management
- *Documentation
- *Escalation Protocol
- *Governance
Key Dates
Compliance Impact
Urgency: HIGH
Who is Affected
Summary
Administrative sanction imposed on the alternative investment fund manager Max Gain Capital S.à r.l. (“AIFM”)