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CSSF announces 2025 AML/CFT questionnaire and upcoming AMLA preparation

04 Dec 2025
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On 1 December 2025, the Commission de Surveillance du Secteur Financier (CSSF) announced the launch of its 2025 Annual AML/CFT Questionnaire on 23 February 2026. This initiative aims to gather standardised information on money laundering and terrorism financing risks faced by entities under CSSF supervision, as well as the measures implemented to mitigate these risks.

The questionnaire is a key component of the CSSF's risk-based supervision approach for combating financial crime.

Key details:
  • Submission deadline: Responses must be submitted via the CSSF eDesk platform by 3 April 2026.
  • Changes in 2025 questionnaire: Updates and new questions have been incorporated, with changes clearly marked.
  • Responsibility for completion:
  • The Compliance Officer in charge of the day-to-day compliance (RC) or the Person responsible for overall compliance (RR) must ensure the questionnaire is completed.
  • Delegation to another employee or third party is permitted, but ultimate responsibility remains with the RC or RR.
  • All involved must have an eDesk account authenticated via LuxTrust.
  • API solution: The Application Programming Interface (API) remains available for submissions, with a user guide accessible on the CSSF website.

Additional Ad Hoc questionnaire:

In the first half of 2026, the CSSF will release an additional questionnaire targeting credit and financial institutions. This will collect data to assist the European Anti-Money Laundering Authority (AMLA) in selecting entities for direct supervision starting 1 January 2028. AMLA plans to directly oversee 40 entities, with the selection process occurring in 2027.

Entities are encouraged to ensure their eDesk accounts are active to avoid connectivity issues.

CSSF’s press release can be found here