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CSSF annual online survey on money laundering and terrorist financing risks

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29 January 2021

On 15 February 2021, the CSSF will launch its annual online survey for the year 2020 to collect standardised key information concerning money laundering and terrorist financing (ML/TF) risks to which supervised professionals are exposed, as well as the implementation of related risk mitigation and targeted financial sanctions measures (the Survey).

Professionals of both the banking and fund sectors are in scope

The survey will have to be answered by the following professionals:

In the banking sector at large: credit institutions, investment firms, payment institutions and electronic money institutions and specialised professionals of the financial sector.

In the investment funds sector: investment fund managers, including registered AIFMs, Luxembourg branches of investment fund managers, SIAG (self-managed investment companies), FIAAG (internally managed AIFs), and investment funds which did not designate an investment fund manager.

All Luxembourg branches of the entities listed above having their registered office in an EU country or a third country.

The content of the survey should generally remain unchanged compared to last year 

In a press release of 24 December 2020, the CSSF indicated that the content of the Survey remains generally unchanged, but a few new questions have been added to cover the changes introduced in the Luxembourg AML/CTF legislation in 2020.

The deadline is 15 March 2021

Answers to the Survey must be submitted by 15 March 2021.

Answers to be provided through the CSSF eDesk portal

Answers to the Survey must be submitted through the CSSF eDesk portal either by the compliance officer in charge of the control of compliance with the professional obligations (the so-called RC) or the person responsible for compliance with the professional obligations (the so-called RR).

Submission may be delegated to another employee of the professional or a third party, but the RC or the RR will remain responsible for the adequate submission of the Survey.

Submission requires an eDesk account and therefore a LuxTrust authentication. The CSSF recommends that the necessary eDesk account be created in advance.

The full text of the circular-letter relating to this Survey can be found here.