Screening, and the framework that changed in December 2025
Circular CSSF 25/896 put governance around screening from 30 December 2025 for the entities in its scope, which does not include funds or their managers. Which lists, which people, which moments, and why resolving a hit matters more than reducing hits.
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The narrated video runs about 1 hour 31 minutes across the 30 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 5. International financial sanctions
Why a prohibition is not calibrated to risk and which authorities sanctions put you in front of under the Law of 19 December 2020, the screening framework made explicit by Circular CSSF 25/896 and the EBA guidelines applicable since 30 December 2025, the discipline of resolving hits rather than reducing them, and what a confirmed match obliges you to do: freeze, do not make funds available, notify the Ministry of Finance, and never release on your own authority.
Every instrument this lesson is built from, linked to its official text
Circular CSSF 25/896 of 18 August 2025 adopts EBA/GL/2024/14 and EBA/GL/2024/15, and section 3 of the circular applies both, and the circular itself, from 30 December 2025. Section 2 sets the scope and it matters here: EBA/GL/2024/14 reaches credit institutions and investment firms under the Law of 5 April 1993 and payment institutions and electronic money institutions under the Law of 10 November 2009; EBA/GL/2024/15 reaches payment service providers and crypto asset service providers as defined in Regulation (EU) 2023/1113. Undertakings for collective investment, management companies and AIFMs are outside that scope, so for a fund entity the circular is the supervisor visible standard rather than an adopted requirement, while the underlying freezing and making-available prohibitions under Council Regulation (EU) 269/2014 and the Law of 19 December 2020 apply to it in full. The EU and UN lists are the baseline to screen against, and both change continuously, so they are read rather than saved.
- Circular CSSF 25/896 of 18 August 2025 Adoption of the EBA guidelines on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures. CSSF document page https://www.cssf.lu/en/Document/circular-cssf-25-896/
- Circular CSSF 25/896, the circular text English version, PDF on cssf.lu https://www.cssf.lu/wp-content/uploads/cssf25_896eng.pdf
- EBA Guidelines EBA/GL/2024/14 and EBA/GL/2024/15 of 14 November 2024 European Banking Authority, guidelines on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures. Applicable from 30 December 2025 https://www.eba.europa.eu/activities/single-rulebook/regulatory-activities/anti-money-laundering-and-countering-financing-terrorism/guidelines-internal-policies-procedures-and-controls-ensure-implementation-union-and-national
- The EU consolidated list of persons, groups and entities subject to financial sanctions European Commission, the overview page carrying the consolidated list managed by DG FISMA and the EU Sanctions Map. The list itself changes continuously, so read it rather than a saved copy https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/overview-sanctions-and-related-resources_en
- The United Nations Security Council consolidated list un.org, the Security Council consolidated list of all individuals and entities subject to UN sanctions measures. Updated continuously as the committees designate and delist https://www.un.org/securitycouncil/content/un-sc-consolidated-list
Module 5. International financial sanctions
- Lesson 5.1. Not the same regime, and why that matters 3:14
- Lesson 5.2. Screening, and the framework that changed in December 2025 3:23 · this page
- Lesson 5.3. A confirmed match, and what happens next 3:15
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