Circular letter
Executive Summary
The CSSF Circular Letter 2026-02-12 announces a standardized data collection exercise on AML/CFT for supervised entities, scheduled for 2026, aimed at enhancing regulatory oversight of money laundering and terrorist financing risks. This matters because it signals intensified CSSF scrutiny on AML/CFT compliance, requiring firms to prepare structured data submissions that could inform future supervisory actions, risk assessments, and enforcement. As part of broader CSSF AML/CFT initiatives, non-compliance risks fines or heightened inspections. #
What Changed
- Introduction of standardized AML/CFT data collection: CSSF mandates uniform reporting formats for collecting data on AML/CFT risks, controls, and practices across supervised sectors, building on existing risk-based supervision frameworks. - Alignment with ongoing AML/CFT enhancements: Complements recent governance-focused circulars (e.g., Circular 26/906 on central administration and risk management for payment/e-money institutions) by emphasizing data-driven validation of AML/CFT effectiveness, including risk assessments, transaction monitoring, and third-party oversight. - No explicit new obligations beyond preparation for data submission, but implies deeper integration of tax-related AML indicators and sub-sector risk updates, as seen in related CSSF activities. #
What You Need To Do
- Assess and document AML/CFT data readiness
- Update governance and controls
- Conduct internal reviews
- Prepare for submission
- Engage auditors
Key Dates
Compliance Impact
Urgency: High – With data collection in 2026 underway today (12 February 2026), firms face immediate preparation needs amid recent enforcement (e.g., EUR 102,000 fine on depositary for AML-related gaps) and conferences signaling sub-sector focus. This elevates AML/CFT as a supervisory priority, potentially triggering on-site inspections, fines, or remediation orders for inadequate data/risks; proa
Who is Affected
Summary
AML/CFT standardised data collection taking place in 2026