On 9 December 2024, the Commission de Surveillance du Secteur Financier (CSSF) announced the launch of its annual online questionnaire for 2024, aimed at collecting standardized key information concerning money laundering and terrorism financing (ML/TF) risks via a communiqué. This initiative is part of the CSSF’s ongoing efforts to assess and mitigate ML/TF risks within the financial sectors under its supervision. 

Key Details: 

  • Launch Date: 24 February 2025 
  • Submission Deadline: 4 April 2025 
  • Submission Platform: CSSF eDesk platform 

The 2024 questionnaire remains largely consistent with the previous year’s version, with certain questions removed, added, or amended. These modifications will be clearly indicated within the questionnaire to facilitate completion. 

Responsibility for completing the questionnaire lies with: 

  • The compliance officer in charge of monitoring compliance with professional obligations (“responsable du contrôle du respect des obligations professionnelles” or “RC”), or 
  • The person responsible for compliance with professional obligations (“responsable du respect des obligations professionnelles” or “RR”). 

While the task of completing the questionnaire can be delegated to another employee or third party within the eDesk platform, the ultimate responsibility remains with the RC or RR.  

The CSSF emphasizes the importance of accurate and timely submission of the questionnaire, as it plays a crucial role in the CSSF’s risk-based supervision approach to AML/CFT. Entities are encouraged to review the user guide and ensure all necessary preparations are in place prior to the questionnaire’s launch. 

Reserved Alternative Investment Funds (RAIFs) and unregulated Alternative Investment Funds (AIFs) fall under the scope of the Administration de l’Enregistrement, des Domaines et de la TVA (AED) survey. As the authority responsible for the supervision and control of other financial entities, the AED oversees AML/CFT compliance for RAIFs and Luxembourg-based AIFs, which are not subject to prudential supervision by the CSSF . The submission deadline for the AED survey will be 30 April 2025 for RAIFs and 30 June 2025 for AIFs. Additional information regarding these entities will be made as soon as available. 

For further information and access to the user guide, please visit the CSSF’s official website (https://www.cssf.lu/en/2024/12/2024-questionnnaire-on-financial-crime/). 

Don’t hesitate to contact our investment management team should you need our assistance regarding your AML_CFT process.