Published on 14 December 2021
Communiqué

2021 Survey related to the fight against money laundering and terrorism financing

The CSSF will start the annual online survey for the year 2021 on 15 February 2022.

The objective is to collect standardised key information concerning money laundering and terrorism financing (ML/TF) risks to which professionals under CSSF supervision are exposed and the implementation of measures to mitigate these risks. This cross-sector survey contributes to the CSSF’s ongoing assessment of ML/TF risks present in the financial sectors under its supervision and forms part of the AML/CFT risk-based supervision approach put in place by the CSSF.

The 2021 survey remains mostly unchanged compared to the previous year. However, some questions have been removed, added or amended. The new questions have been highlighted in the survey.

Answers to the survey questions will have to be submitted through the CSSF eDesk Portal by 15 April 2022 (at the latest).

The survey must be initiated and submitted within the CSSF eDesk Portal by:

– the compliance officer in charge of the control of compliance with the professional obligations1 (“responsable du contrôle du respect des obligations professionnelles” (“RC”)), or

– the person responsible for compliance with the professional obligations2 (“responsable du respect des obligations professionnelles” (“RR”)).

The completion of the survey, however, may be assigned within the CSSF eDesk Portal to another employee of the entity or third party, while bearing in mind that the ultimate responsibility for the adequate completion of the survey shall remain with the “RC” or the “RR”.

In terms of logistics, this implies that the aforementioned person and their potential delegates must have an eDesk account, which requires a LuxTrust authentication.

In order to avoid connection problems when the survey will be launched, the CSSF invites all entities it supervises for AML/CFT purposes to ensure they have an account. Reference is made to the “Authentication and user account management” user guide in the dedicated section of the CSSF eDesk Portal homepage for further details.

1 As per Article 1 (1) of the CSSF Regulation N°12-02 of 14 December 2012 on the fight against money laundering and terrorist financing as amended by CSSF Regulation No 20-05 of 14 August 2020

2 As per Article 1 (1) of the CSSF Regulation N°12-02 of 14 December 2012 on the fight against money laundering and terrorist financing as amended by CSSF Regulation No 20-05 of 14 August 2020

Circular letter published on 31 January 2022: 2021 survey related to the fight against ML/TF