Circular letter
Executive Summary
The CSSF circular letter dated 11 March 2026 announces a delay in its planned AML/CFT standardised data collection exercise originally scheduled for 2026, primarily due to overlap with a concurrent broad-scope data collection by the European Anti-Money Laundering Authority (AMLA). This matters for compliance professionals as it reduces immediate reporting burdens on supervised entities, promotes regulatory simplification, and aligns Luxembourg practices with emerging EU AML/CFT methodologies, allowing firms to redirect resources to the mandatory AMLA exercise. #
What Changed
- Postponement of CSSF-specific questionnaire: The CSSF has decided not to proceed with its own AML/CFT standardised data collection for most supervised entities (credit institutions, investment firms, investment fund managers), opting instead to rely on AMLA's questionnaire to avoid duplication and ensure a level playing field. - Exception for specialised professionals: Specialised professionals of the financial sector (e.g., certain non-credit institutions) remain subject to a CSSF-specific questionnaire, though timelines are affected by the delay announcement. - Rationale tied to AMLA calibration exercise: Entities selected for AMLA's 2026 calibration exercise (notified directly by CSSF) must complete it regardless; non-selected entities were to use AMLA templates via CSSF's eDesk, but
What You Need To Do
- Monitor CSSF updates
- Prioritize AMLA obligations
- Specialised professionals
- Internal review
- No immediate submissions
Key Dates
Compliance Impact
Urgency: Medium. The delay alleviates short-term pressure by postponing submissions and reducing dual reporting, enabling resource reallocation to higher-priority AMLA efforts amid EU harmonization. It matters for maintaining a risk-based approach (RBA) under FATF standards, avoiding overburden from overlapping exercises, and preparing for the new EU AML/CFT methodology—non-compliance risks superv
Who is Affected
Summary
Delay in the 2026 AML/CFT standardised data collection