Administrative sanction of 11 September 2025
Executive Summary
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager C5 Haven Cyber GP S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores CSSF's strict enforcement of reporting duties in AML/CFT compliance, serving as a warning to supervised entities on the consequences of administrative delays. It matters because it highlights low-tolerance for even minor procedural lapses, potentially signaling increased scrutiny on annual reporting amid broader AML/CFT priorities. #
What Changed
This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended AML/CFT Law: - Article 5(1) mandates supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, to cooperate fully with CSSF, including submitting the annual financial crime questionnaire ("Questionnaire"). - Breach occurred due to non-submission of the 2024 year-end Questionnaire, with fine determined per Articles 8-4(1), 8-4(2)(f), 8-4(3)(a), and 8-5(1). - Publication of the sanction follows Article 8-6(1), after proportionality assessment to avoid market stability risks. No new rules introduced; reinforces ongoing duty to meet CSSF reporting timelines without justification for delays. #
What You Need To Do
- Review and confirm timely submission of all pending or future CSSF financial crime questionnaires; establish automated calendar reminders for annual deadlines (e
- Implement escalation protocols for CSSF reminders, ensuring immediate response and submission within days, not weeks
- Conduct internal audit of AML/CFT cooperation obligations, documenting justifications for any delays and preparing evidence for potential CSSF hearings or meetings
- Update compliance policies to prioritize Article 5(1) duties, including training for responsible persons on fine risks under Article 8-4
Key Dates
Compliance Impact
Urgency: Medium - Matters due to CSSF's demonstrated willingness to impose and publicize fines for straightforward reporting failures, even at €10,000, which could escalate for repeat or severe cases; acts as a precedent amid rising AML/CFT enforcement (e.g., larger fines like €214,000 in similar contexts). Firms delaying submissions risk reputational damage from nominative publications under Arti
Who is Affected
Summary
Administrative sanction imposed on the alternative investment fund manager C5 S.à r.l. (“AIFM”)