Today, the Commission de Surveillance du Secteur Financier – Luxembourg financial services regulator (“CSSF”), being the supervisory authority in Luxembourg responsible for ensuring AML/CFT compliance by professionals under the CSSF’s supervision, published that it shall be launching its annual AML/CFT Questionnaire on Financial Crime (the “Questionnaire”) covering the 2025 year on 23 February 2026, whereby the final submission of responses has to be completed by latest 3 April 2026.
The objective of the Questionnaire is to enable the CSSF to collect uniform key information and data concerning money laundering and terrorism financing (“ML/TF”) risks to which professionals under its supervision are exposed, and the implementation of the corresponding mitigation measures to lessen these risks. This Questionnaire forms part of the CSSF’s ongoing assessment of ML/TF risks present in the financial sector under its supervision and is a vital contributing factor of the AML/CFT risk-based supervision approach established by the CSSF.
The Questionnaire must be completed through the CSSF eDesk platform by the responsable du contrôle du respect des obligations professionnelles – compliance officer in charge of the control of compliance with the professional obligations (the “RC”), or the responsable du respect des obligations professionnelles – person responsible for compliance with the professional obligations (the “RR”). However, the completion of the Questionnaire may be assigned to another employee of the entity or third party, while bearing in mind that the ultimate responsibility for the adequate completion of the Questionnaire shall remain with the RC, or the RR.
On a separate note, the CSSF has also published that an additional, ad hoc questionnaire will be launched throughout the first half of the upcoming year (2026) in parallel to the Questionnaire, whereby this ad hoc questionnaire shall be applicable to credit and financial institutions, to collect data for the selection of the eligible financial sector entities that will be directly supervised by the Anti-Money Laundering Authority (“AMLA”) starting on 1 January 2028. In this respect, further information will be provided by the CSSF in due course.
Should you require any clarifications on the above, or require assistance in the compilation of the CSSF Questionnaire on Financial Crime going forward, kindly contact Natalia Hernandez or Jonathan Camilleri.
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