2024 Questionnaire on Financial Crime

The CSSF will start its annual online questionnaire for the year 2024 on 24 February 2025.

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 2024 questionnaire remains mostly unchanged compared to the previous year. However, some questions have been removed, added, or amended. 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 4 April 2025 (at the latest).

The Application Programming Interface (“API”) solution, used for the first time in 2024 for the 2023 questionnaire, is still applicable. The API solution is based on the use of a structured exchange file (json format) to be transmitted to the CSSF via the S3 (“simple storage service”) protocol. This file will then pre-fill the questionnaire available on the CSSF eDesk platform. The entity will also be able to update directly in eDesk the data prefilled through S3. The manual input of the responses directly in the eDesk online form remains possible.

The technical guidance including enrolment process is accessible through the following link Methods of transmitting reports via S3 Application Programming Interface – Technical guidance – CSSF. The user guide containing the technical details (json schema, naming convention) will be available later.

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.