In a press release dated 22 November 2023, the CSSF announced its 2023 Financial Crime Survey ("2023 Survey") will start on 19 February 2024.
Scope of application
All financial professionals and entities subject to the supervision of the CSSF are required to participate in the 2023 Survey.
The aim is to collect key information on the money laundering and terrorist financing (“ML/TF”) risks faced by professionals subject to CSSF supervision, and on the implementation of measures to mitigate these risks.
Key changes
Overall, there are few changes in the 2023 survey compared to the previous year. The main changes are:
- An update to the list of countries with the addition of Palestine to the list (ISO code PS).
- The CSSF has updated questions; indeed, some questions have been removed, added, or amended.
- Set up by the CSSF of an innovative Application Programming Interface (“API”) to streamline data submission. The API solution is based on the use of a structured exchange file to be submitted to the CSSF. This file will then pre-fill the survey available on the CSSF eDesk platform. The entity will also be able to update directly in eDesk. The CSSF specifies that a dedicated user guide will soon be made available. It will include technical details as well as the enrolment process.
By whom is the 2023 Survey to be submitted?
The CSSF points out that the completion of the survey, 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 "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”)).
By when is the 2023 Survey to be submitted?
The CSSF reminds that the final submission to the survey questions will have to be completed through the CSSF eDesk Portal by 1 April 2024 at the latest.
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