The CSSF published a FAQ on March 17, 2022 regarding international financial sanctions (FAQ) as it is the authority responsible for the supervision of the professionals falling under its scope for the compliance of the Law of December 19, 2020 on the implementation of restrictive measures in financial matters (2020 Law),

The CSSF reminds that professionals need to comply with the 2020 Law, and with the CSSF Regulation 12-02 on the fight against money laundering and terrorist financing as modified (CSSF Regulation 12-02) as well as consider the UN and European regulatory framework regarding financial restrictive measures which are directly applicable in Luxembourg.

Following Questions 3, 4 and 5,  professionals are required to report by email (sanctions@fi.etat.lu) or by post (Ministère des Finances, 3 Rue de la Congrégation, L-1352 Luxembourg) to the Ministry of Finance, with in copy the CSSF (adm_jurcc@cssf.lu), without delay of measures taken by professionals that are formal restrictive measures in financial matters.

“Restrictive measures in financial matters” means (1) the prohibition or restriction of financial activities of any kind, (2) the prohibition or restriction on the provision of financial services, technical assistance, training or advice in relation to a State, natural or legal person, entity or group referred to in the 2020 law or (3) the freezing of funds, assets or other economic resources owned or controlled, directly, indirectly or jointly, with or by a person, entity or group referred to in the 2020 Law or by a person acting on their behalf or at their direction. In respect of the freezing of funds, specific forms can be found on the website of the Ministry of Finance or of the CSSF.

The CSSF also indicates that under the Law of November 12, 2004 on the fight against money laundering and terrorist financing, if in relation with the relationship, to which the professional has to apply financial restrictive measures, the professional also identifies a suspicion of money laundering or terrorism financing or an associated predicate offence, the professional shall also inform without delay the Luxembourg FIU via the platform goAML (https://justice.public.lu/fr/organisation-justice/crf/goaml.html) (Question 9).

The CSSF’s FAQ can be found at : https://www.cssf.lu/wp-content/uploads/FAQ_International_financial_sanctions.pdf

For more information, please get in touch with our investment management team.