Circular letter
Executive Summary
This CSSF circular letter addresses the 2026 AML/CFT standardised data collection exercise, aligning with AMLA's EU-wide initiatives by adopting AMLA-developed templates for most supervised entities while requiring specialised professionals to use CSSF-specific forms. It matters for Luxembourg financial firms as it mandates reporting on ML/TF risks and mitigation measures to support consistent EU supervision, with recent delays emphasizing preparation needs amid evolving templates. #
What Changed
- - CSSF adopts AMLA-developed data collection templates for credit institutions, investment firms, and investment fund managers (excluding specialised professionals), replacing its prior questionnaire to avoid duplication with AMLA's broad exercise an
- Entities selected for AMLA's mandatory calibration exercise (notified directly by CSSF) must report quantitative and qualitative ML/TF risk data; non-selected entities still report via AMLA templates on 2025 risks.
- Launch delayed from 2 March 2026 due to AMLA's consultation feedback on templates and guidance; new timelines and final questionnaire to be announced, but AMLA maintains 15 April 2026 submission for sampled entities.
- Specialised professionals of the financial sector complete a separate CSSF questionnaire, launching earlier on 23 February 2026 (subject to delay).
Suggested Considerations
- Monitor CSSF communications for final questionnaire, launch dates, and eDesk access; prepare data on 2025 ML/TF risks and mitigation using current AMLA draft (not for submission).
- Selected AMLA calibration participants: Compile and submit quantitative/qualitative data via eDesk by 15 April 2026; attend 13 March webinar.
- Non-selected credit/financial institutions: Complete AMLA templates on ML/TF risks/mitigation for 2025 via eDesk upon launch.
- Specialised professionals: Prepare CSSF-specific questionnaire ahead of (delayed) 23 February launch.
- All: Ensure resources for timely reporting; review internal AML/CFT risk assessments for consistency with EU standards.
Key Dates
Compliance Impact
Urgency: High - Mandatory reporting supports CSSF's supervisory strategy and EU AMLA calibration, with non-compliance risking enforcement; delays provide preparation time but require immediate data readiness as final deadlines approach shortly (e.g., potential April submissions). This directly feeds into entity-level ML/TF risk assessments, influencing ongoing supervision and resource allocation.
Who is Affected
References
AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.
Summary
Latest update on the AML/CFT standardised data collection