On April 20th 2018, the CSSF published a press release stating that they will be conducting an annual online survey of entities subject to its supervision and subject to the law of 12 November 2004 on the fight against money laundering and terrorist financing, as amended.
This survey, which will comprise sector specific questionnaires, will compile key information in relation to risks associated with money laundering and terrorist financing and the measures put in place to mitigate those risks.
The CSSF has announced that they will be using these surveys after recommendations from the Financial Action Task Force (“FATF”) which proposed that Member States should “apply a risk-based approach (“RBA”) to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the risks identified”.
In addition to allowing the CSSF to assess whether the preventative and mitigation measures put in place by supervised entities are commensurate with the related money laundering or terrorist financing risks, the surveys should allow the CSSF to draw conclusions on the national money laundering/terrorist financing risk assessment.
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