Annex to Circular CSSF 22/822

What Changed

• - CSSF republished the annex to Circular CSSF 22/822 in a Version of 19 June 2026, meaning firms should treat this as the current Luxembourg reference point for FATF jurisdiction screening and country-risk assessment.
• The annex distinguishes between high-risk jurisdictions subject to enhanced due diligence and, where appropriate, counter-measures, and jurisdictions under increased monitoring that require heightened risk awareness but are not automatically subject
• The publication incorporates the FATF’s current statements on jurisdictions with strategic AML/CFT/CPF deficiencies, which is the basis for operational country-risk controls used by Luxembourg-supervised firms.
• The related Circular CSSF 22/822 remains the framework document that instructs professionals to use FATF statements when assessing jurisdictional ML/TF/PF risk.

Suggested Considerations

• Review your AML/CFT country-risk methodology and update it to reflect the 19 June 2026 FATF/CSSF jurisdiction list.
• Re-screen customers, beneficial owners, counterparties, and transactions against the updated high-risk and monitored jurisdiction lists.
• Apply enhanced due diligence for relationships and transactions involving high-risk jurisdictions, and escalate where counter-measures may be required.
• Reassess risk ratings for customers linked to jurisdictions under increased monitoring and document the rationale for any continued onboarding, retention, or exit decisions.
• Update automated screening rules, transaction-monitoring scenarios, and onboarding checklists so they use the current CSSF annex version.
• Ensure AML files, policies, and procedures reference Circular CSSF 22/822 and its latest annex rather than older versions.

Key Dates

Who is Affected