On 29 November 2019 the Commission de Surveillance du Secteur Financier (CSSF) announced that, similarly to last year’s exercise, an annual online survey collecting standardised key information concerning ML/FT risks which the professionals under supervision are exposed to and the implementation of relevant risk mitigation and targeted financial sanctions measures as per 31 December 2019 will be launched in early February 2020.
The survey is hosted on the CSSF eDesk platform and answers will have to be submitted through the portal within a period of six weeks at the latest.
We would like to highlight that the launch and submission of the survey must be executed by the person responsible for compliance with the professional obligations as regards the fight against money laundering and terrorist financing (In French: “responsable du respect des obligations”, the acronym “RR” is used) or by the compliance officer at the appropriate hierarchical level (the original French version of the law refers to a “responsable du contrôle du respect des obligations”, the acronym “RC").
Additional information on these persons can be found in the CSSF Frequently Asked Questions issued on 25 November 2019 – direct link can be found here. The filling in of the survey may be delegated within the CSSF eDesk portal to another employee of the entity or to a third party.
The press release can be found here.