On 31 January 2020, the CSSF published a circular-letter (the “Letter”) on the annual online survey for the year 2019 collecting standardised key information concerning money laundering and terrorist financing (ML/FT) risks to which the professionals under supervision are exposed (the “Survey”). The Letter is addressed to management boards or/and the board of directors of (i) credit institutions, (ii) investment firms, (iii) AIFMs (included registered AIFMs), (iv) UCITS management companies, (v) investment funds which did not designate an investment fund manager, (vi) payment institutions and electronic money institutions, and (vii) specialised professionals of the financial sector incorporated under the Luxembourg law as well Luxembourg branches of the abovementioned entities having their registered office in an EU country or a third country.
Referring to the press release 19/57 issued on 28 November 2019 which first announced the Survey, the Letter reminds that the Survey will open for completion on the CSSF’s eDesk portal on 3 February 2020. Answers to all questions will need to be submitted exclusively through the portal by 15 March 2020 (with the exemption of the banking sector for which deadline is 2 March 2020).
The Survey must be initiated and submitted by a member of the Authorised Management of the entity or the AML/CTF Compliance Officer who is responsible for AML/CTF compliance. Persons responsible for completion of the Survey are required to have the eDesk portal account and the LuxTurst certification necessary to register on the portal. Further guidance is available on the eDesk Portal.