Questionnaire 2025 sur la criminalité financière (uniquement en anglais)

The CSSF will launch its annual online questionnaire for the year 2025 on 23 February 2026.

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 questionnaire contributes to the CSSF’s ongoing assessment of ML/TF risks present in the financial sector under its supervision and forms part of the AML/CFT risk-based supervision approach put in place by the CSSF.

The 2025 questionnaire is subject to some changes compared to the previous year. The new and amended questions have been indicated in the questionnaire.

The final submission of the questionnaire will have to be completed through the CSSF eDesk platform by 3 April 2026 (at the latest).

As in previous years, the Application Programming Interface (“API”) solution is still applicable. The API user guide is again available under the following link: Methods of transmitting reports via API – CSSF.

The questionnaire must be completed within the CSSF eDesk platform 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 questionnaire, however, may be assigned within the CSSF eDesk platform to another employee of the entity or third party, while bearing in mind that the ultimate responsibility for the adequate completion of the questionnaire shall remain with the “RC” or the “RR”. This implies that the aforementioned person and his/her potential delegate hold an eDesk account, which requires a LuxTrust authentication.

In order to avoid connection problems when the questionnaire 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 “eDesk – Authentication – User Guide” on the CSSF eDesk Portal homepage for further details.

Moreover, the CSSF would like to make obliged entities aware that an additional, ad hoc questionnaire will be launched in the first half of the year 2026 in parallel to the Questionnaire on Financial Crime. This ad hoc questionnaire, addressed to credit and financial institutions, will collect data to prepare the selection of the financial sector entities that will be directly supervised by the new European Anti-Money Laundering Authority (“AMLA”) starting on 1 January 2028. Specifically, data may be requested on the free provision of services. This data will be communicated to AMLA and used amongst others for the preliminary selection of eligible entities for direct supervision. AMLA is expected to select, during 2027, 40 obliged entities to be directly supervised³. Further information will be provided by the CSSF as soon as possible.