The Luxembourg financial regulator, the Commission de Surveillance du Secteur Financier (CSSF), has issued administrative fines to five alternative investment fund managers for failing to comply with anti-money laundering and counter-terrorism financing (AML/CFT) regulations.
Each firm was fined 10,000 euros following a failure to submit required financial crime questionnaires by the set deadline of April 2, 2024, despite multiple reminders from the regulator.
The five firms sanctioned by the CSSF are:
1. LDX Asset Management Sàrl.: The CSSF imposed the fine on August 28, 2024, citing the firm’s non-compliance with its duty to submit the financial crime questionnaire for the year ending December 31, 2023.
2. Cardea International Management SA: This firm received a similar fine for failing to meet its AML/CFT obligations as mandated under Luxembourg law, as it also did not submit the questionnaire by the deadline.
3. Fonds AAA Sàrl: The CSSF found Fonds AAA in breach of the AML/CFT law for its failure to comply with the mandatory submission of the financial crime questionnaire, resulting in the 10,000-euro fine.
4. Global Investment Opportunities Partners: Like the others, Global Investment Opportunities Partners failed to submit the required documentation on time, leading to the CSSF’s decision to impose an identical penalty.
5. Sophont Management: Also for failing to submit the required answers by 2 April.
These fines underscore the CSSF’s commitment to enforcing AML/CFT compliance within Luxembourg’s alternative investment sector, aiming to enhance transparency and mitigate financial crime risks.