The coercive fine, and what it costs to ignore one
The coercive fine is capped and survivable. Failing to act on an injunction is a ground for sanction in its own right, and the published decisions show what that costs.
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The narrated video runs about 45 minutes across the 18 lessons. That is short on purpose: no filler and no reading out of the law, with the work in the transcripts, the sources, the assessments and the artefacts.
Module 2. The injunction, the fine and the inspection
The injunction and the deadline that is in your letter rather than in a statute, the coercive fine alongside the much larger risk of not answering at all, and how an on-site inspection runs from the annual plan through the fact validation meeting to the observation letter. Lesson 2.1, the injunction, and the clock it starts. Lesson 2.2, the coercive fine, and what it costs to ignore one. Lesson 2.3, how an on-site inspection actually runs.
Every instrument this lesson is built from, linked to its official text
Article 63(3) of the Law of 5 April 1993 is the coercive fine, capped at 1,250 euros a day and 25,000 euros in total. Article 63(1) makes a failure to act on an injunction, or to comply with a decision of the CSSF, a ground for sanction in itself, and article 63(2) is the scale. The Law of 5 May 2026 inserted paragraphs 4 to 6 into article 63, which are the far larger periodic penalty payments. They are confined twice over: to the cases in articles 63-1 and 63-2, and to CRR institutions, financial holding companies and mixed financial holding companies and the individuals named in article 63(4). An investment fund manager or a UCI is none of those, so paragraphs 4 to 6 cannot reach it. The four decisions are the published record referred to in the lesson.
- Law of 5 April 1993 on the financial sector Consolidated version published by the CSSF. Article 53 carries the supervisory and investigatory powers, including the duty to state reasons in paragraph 4, article 59 the injunction and suspension powers, article 63 and its lettered articles the sanctions, the coercive fine, publication and the right of appeal, article 63-4 the factors taken into account in setting a penalty, and article 64-2 the reporting of certain sanctions to the European Banking Authority https://www.cssf.lu/en/Document/law-of-5-april-1993/
- Law of 5 May 2026 amending, among others, the Law of 5 April 1993 on the financial sector Memorial A n. 227, Legilux. Transposes Directive (EU) 2024/1619 and inserts the periodic penalty payments into article 63 for the cases in articles 63-1 and 63-2 https://legilux.public.lu/eli/etat/leg/loi/2026/05/05/a227/jo
- CSSF administrative sanction of 11 September 2025, Agriland Management S.A., EUR 10,000 CSSF publication and data. Failure to submit the questionnaire on financial crime for the year ending 31 December 2024, a breach of the duty to cooperate in article 5(1) of the Law of 12 November 2004 https://www.cssf.lu/en/Document/administrative-sanction-of-11-september-2025-4/
- CSSF administrative sanction of 11 September 2025, Lion Management, EUR 10,000 CSSF publication and data. The same breach on the same date, published nominatively under article 8-6(1) https://www.cssf.lu/en/Document/administrative-sanction-of-11-september-2025-6/
- CSSF administrative sanction of 16 July 2025, Zeus Asset Management S.A., EUR 18,136 CSSF published decision. Insufficient cooperation is recorded among the factors taken into account https://www.cssf.lu/en/Document/administrative-sanction-of-16-july-2025/
- CSSF administrative sanction of 23 July 2025, JTC (Luxembourg) S.A., EUR 102,000 CSSF published decision. The decision records in mitigation that the entity identified the failings itself before being alerted https://www.cssf.lu/en/Document/administrative-sanction-of-23-july-2025/
Module 2. The injunction, the fine and the inspection
- Lesson 2.1. The injunction, and the clock it starts 2:41
- Lesson 2.2. The coercive fine, and what it costs to ignore one 2:45 · this page
- Lesson 2.3. How an on-site inspection actually runs 3:07
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