2023 Survey on Financial Crime
The CSSF will start the annual online survey for the year 2023 on 19 February 2024.
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 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. Specifically, please take advance notice that the Country List has been modified with the addition of Palestine (ISO Code PS) so that you can anticipate the modification of related data extracts.
The final submission to the survey questions will have to be completed through the CSSF eDesk Portal by 1 April 2024 (at the latest).
Please note that for the 2023 Financial Crime survey campaign, the CSSF will make available a new Application Programming Interface (“API”) solution allowing to pre-populate the survey in order to ease the process. The API solution is based on the use of a structured exchange file (json format) to be transmitted to the CSSF via the S3 (“simple storage service”) protocol. This file will then pre-fill the survey available on the CSSF eDesk platform. The entity will also be able to update directly in eDesk the data prefilled through S3. The manual input of the responses directly in the eDesk online form remains possible.
A dedicated user guide will soon be made available. It will include technical details (json schema, naming convention) as well as the enrollment process. The enrollment at CSSF will only be required once entities are ready to test the developments.
The survey must still be completed 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 N° 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 N° 20-05 of 14 August 2020