On 3 February 2020, the Luxembourg financial regulator, the CSSF, launched its annual AML/CTF (anti-money laundering and counter-terrorist financing) online survey for 2019. This survey is the second of its kind. The CSSF had announced in spring 2018 that it would conduct annual online surveys collecting standardised key information concerning money laundering and terrorist financing risks to which the professionals under its supervision are exposed and would implement related risk mitigation and targeted financial sanctions measures. The first 2018 survey was conducted in February 2019. In substance, the 2019 survey is the same as last year’s version.
Besides banks and other financial institutions, the survey is directed at Luxembourg investment fund managers (IFM) (that is, UCITS management companies and AIFMs (including registered AIFMs)), Luxembourg branches of IFM (but not those foreign IFMs which manage Luxembourg funds without having established a branch in Luxembourg), SIAG (self-managed UCITS), FIAAG (internally managed AIFs with a full AIFMD authorisation), and (regulated) investment funds which have not designated an IFM.
The affected entities will have to submit their response to the survey questions through the CSSF eDesk portal by 15 March 2020. For banks, the deadline is 2 March 2020.
From a practical perspective, the CSSF requires that (a) a member of management or, preferably, (b) the AML/CTF Compliance Officer who is responsible for AML/CTF compliance, initiate and submit the self-assessment ML/FT risk survey via the CSSF eDesk portal. The completion of the survey, however, may be assigned to another employee of the affected entity. In terms of logistics, this implies that the aforementioned persons and their potential delegates must create an eDesk account (if they do not already have one) which requires a LuxTrust authentication.
Please let us know if you require any assistance in completing this survey or if you have any other queries.