Live Updates

Circular letter

AI Analysis

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.

Key dates

2026 (exact date TBD) Deadline
AML/CFT standardised data collection exercise; Firms must submit required data during this period; preparation recommended immediately given today's date (12 February 2026)
20 January 2026 Deadline
Issuance of related Circular 26/906; Establishes governance baselines (e.g., compliance independence, risk proportionality) informing data collection expectations
26 January 2026
CSSF AML/CFT Conference for Specialised PFS; Provided updates on sub-sector risks, terrorist financing reviews, and FIU insights relevant to data preparation
28 January 2026 Deadline
Conference materials published; Available for download to guide compliance alignment

Suggested considerations

  • Assess and document AML/CFT data readiness: Inventory current risk assessments, transaction monitoring logs, KYC processes, SAR filings, and third-party oversight records in standardized formats; map to proportionality factors (e.g., transaction volumes, outsourcing).
  • Update governance and controls: Ensure compliance functions have independence, direct board reporting, and audit coverage of AML/CFT; test ICT resilience for monitoring continuity.
  • Conduct internal reviews: Perform gap analyses against Circular 26/906 (e.g., fund safeguarding, escalation protocols) and recent conference topics (e.g., terrorist financing, tax indicators); remediate deficiencies with board-approved plans.
  • Prepare for submission: Designate resources for data compilation; cooperate fully with CSSF/FIU requests, including transfer-of-funds information under EU 2015/847.
  • Engage auditors: Leverage approved auditors for validation of AML/CFT effectiveness ahead of collection.

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 effec
  • 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.

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

  • Primary
  • supervised financial professionals, including banks, payment institutions, electronic money institutions, account information service providers, specialised Professional of the Financial Sector (PFS), investment firms, and insurers subject to AML/CFT obligations.
  • Secondary
  • party providers involved in outsourcing AML/CFT functions.
  • Broad applicability
  • based AML/CFT measures and cooperate with CSSF/FIU.
  • CSSF Circular 26/906 (20 Jan 2026)
  • Circular-26-906/)1
  • CSSF AML/CFT Conference for Specialised PFS (26 Jan 2026)
  • back-on-the-2026-cssf-aml-cft-conference-for-specialised-pfs/)3
  • CSSF AML/CFT Supervision Framework
  • money-laundering-and-countering-the-financing-of-terrorism/)2

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

What the CSSF said

AML/CFT standardised data collection taking place in 2026

Published by CSSF . Read the full notice at the source for the authoritative text.

Relevant Firm Types

BankPayment Provider
View Original on CSSF Back to Feed

Share this update