The CSSF will start the annual online survey for the year 2020 on 15 February 2021.
The objective is to collect standardised key information concerning money laundering and terrorist 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 over the last years.
The 2020 survey remains generally unchanged compared to the previous year. However, few new questions have been added following the amendment to the 2004 AML/CFT Law in March 2020.
Answers to the survey questions will have to be submitted through the CSSF eDesk portal by 15 March 2021.
The self-assessment ML/TF risk survey must be initiated and submitted 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 “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