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ARTICLE · 22 JANUARY 2025

AML/CTF Asset Due Diligence Obligations: CSSF Provides Clarifications In An Initial Q&A

Goodwin Procter LLP
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On 13 December 2024, the Commission de Surveillance du Secteur Financier (CSSF) published the first FAQ to assist professionals in the investment sector supervised, authorised...

LuxembourgGovernment, Public Sector
Codrina Constantinescu
Codrina Constantinescu
Céline Moille
Céline Moille

Overview

On 13 December 2024, the Commission de Surveillance du Secteur Financier (CSSF) published the first FAQ to assist professionals in the investment sector supervised, authorised, or registered by the CSSF in complying with Luxembourg's anti-money laundering and counter-terrorism financing (AML/CTF) asset due diligence obligations.

The FAQ provides detailed guidance on the scope and frequency of ML/TF risk assessments and related AML/CTF due diligence measures to be performed pursuant to a risk-based approach. It distinguishes between:

  • Listed Assets: Assets traded on regulated markets (as defined by MiFID1)
  • Unlisted Assets: Assets not traded on such markets

While professionals under CSSF supervision (including Luxembourg investment fund managers and investment funds supervised by the CSSF for AML/CTF purposes) must comply with these rules, the FAQ also offers valuable insights for professionals (as this term is defined by the Law of 12 November

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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