CSSF annual survey on financial crime

In a Communication dated 22 November 2023, the CSSF announced that the annual online survey on financial crime would begin on 19 February 2024.

As a reminder, the objective of this survey is to collect standardised key information concerning money laundering and terrorism financing (“ML/TF”) risks to which professionals under CSSF supervision (i.e. notably AIFMs, including registered AIFMs, and UCITS ManCos) are exposed and the implementation of measures to mitigate these risks.

The 2023 survey remains mostly unchanged compared to the previous year. However, some questions have been removed, added, or amended. The new and amended questions have been highlighted in the survey (e.g. the country list has been modified with the addition of Palestine).

The deadline for the final submission of answers to the survey questions is  1 April 2024.

For this survey, the CSSF will make available a new Application Programming Interface (API) solution allowing to pre-complete the survey in order to ease the process and a dedicated user guide will soon be made available.

The survey must be completed within the CSSF eDesk Portal either by:

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

From a practical point of view, the completion of the survey may be assigned within the CSSF eDesk Portal to another employee of the entity or third party, however, the ultimate responsibility for the adequate completion of the survey shall remain with the RC or the RR.