The annual online questionnaire for the year 2023 collecting standardised key information concerning money laundering and terrorism financing risks to which the supervised professionals are exposed and the implementation of the related risk mitigation and targeted financial sanctions measures was launched on 19 February 2024.

The 2023 questionnaire remains mostly unchanged compared to the previous year. However, some questions have been removed, added, or amended.
Answers to the questions will have to be submitted through the CSSF eDesk portal by 2 April 2024 (at the latest) by:

  • the compliance officer in charge of the control of compliance with the professional obligations (“responsable du contrôle du respect des obligations professionnelles” (“RC”), or
  • the person responsible for compliance with the professional obligations (“responsable du respect des obligations professionnelles” (“RR”).

The completion of the questionnaire may be assigned within the CSSF eDesk portal to another employee of the entity or third party, while the ultimate responsibility for the adequate completion of the questionnaire shall remain with the “RC” or the “RR”.

For the 2023 Financial Crime questionnaire campaign the CSSF will provide a new Application Programming Interface (“API”) solution allowing to pre-populate the questionnaire in order to ease the process.

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 the data prefilled directly in eDesk through S3. The manual input of the responses remains possible directly in the eDesk online form.

Sources: https://www.cssf.lu/en/2023/11/2023-survey-on-financial-crime/

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