Annex of Circular CSSF 22/822
Executive Summary
The Annex of Circular CSSF 22/822 (Version of 17 February 2026) is Luxembourg's Commission de Surveillance du Secteur Financier's implementation guidance on FATF (Financial Action Task Force) designations of high-risk jurisdictions requiring enhanced due diligence and counter-measures, as well as jurisdictions under increased monitoring. This document is critical for Luxembourg-regulated financial institutions because it operationalizes international AML/CFT standards into binding compliance obligations, directly impacting customer acceptance, transaction monitoring, and correspondent banking relationships.
What Changed
The current version (17 February 2026) represents the most recent update to the CSSF's FATF-aligned jurisdiction risk framework. Based on the available search results, the document establishes two primary regulatory categories: High-Risk Jurisdictions (Category 1): Jurisdictions designated by FATF as having strategic deficiencies in their AML/CFT regimes, requiring enhanced due diligence and, where appropriate, counter-measures. The search results specifically reference Iran and Myanmar as examples, with Iran subject to the most stringent measures including restrictions on establishing branches or representative offices. Increased Monitoring Jurisdictions (Category 2): Jurisdictions under FATF increased monitoring that have developed action plans to address AML/CFT deficiencies. The doc
Suggested Considerations
- *For High-Risk Jurisdictions:
- Apply enhanced due diligence and monitoring measures to business relationships and transactions with designated jurisdictions
- Increase the frequency and timing of transaction controls
- Select transaction patterns requiring further examination and obtain detailed information on transaction purposes
- Maintain enhanced mechanisms for reporting suspicious activity to the FIU
- For Iran specifically: implement increased supervision of subsidiaries and branches, enhanced control measures, systematic reporting of financial transactions, and increased external audit for financial groups
Key Dates
Compliance Impact
Urgency: CRITICAL
Who is Affected
References
AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.
Summary
1) high-risk jurisdictions on which enhanced due diligence and, where appropriate, counter-measures are imposed2) jurisdictions under increased monitoring of the FATFVersion of 17 February 2026