Following the "UCI On-Site inspections", the CSSF
concluded that the mitigation measures put in place regarding the
tax offences were satisfactory. However, the professional shall
strengthen their policies and practices regarding the integration
of tax offences in their risk assessment, the risk-based approach
in compliance monitoring plan and internal audit plan, as well as
the monitoring of tax compliance obligations in the context of a
delegation.
On 8 November 2022, the Commission de Surveillance du
Secteur Financier (CSSF) published a statement regarding the
AML/CFT controls applied for preventing tax offences.
Following the Law of 23 December 2016, the money laundering
offence was extended to encompass aggravated tax fraud (fraude
fiscale agravée) and tax evasion (escroquerie
fiscal). Therefore, the professionals shall consider the tax
crimes within the scope of their due diligence and professional
obligations in terms of anti-money laundering and
