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Courses/ AML/CFT/ Module 6/ Lesson 6.3
Lesson 3 of 3 · Module 6

What changed in 2026

The CSSF replaced its own questionnaire with AMLA data collection templates. What that says about where supervision is heading, and how few entities the AMLA will ever supervise directly.

3:01 Module 6. Reporting and supervision AML/CFT and KYC in Luxembourg practice
The video and the full transcript of this lesson are part of the course This page is the description of the lesson: what it is about, how long it runs and every instrument it is built from. Watching it and reading it word for word need an account with access to AML/CFT and KYC in Luxembourg practice. Two lessons of this course are open to everyone with no account and no payment.
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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.

What Module 6 covers

Module 6. Reporting and supervision

The market entry form submitted once for the umbrella rather than once per sub-fund and what actually triggers a new filing, the annual self assessment reconciled with the auditor before either is filed, the financial crime questionnaire that two entities were fined ten thousand euros each for not submitting, and the 2026 replacement of that questionnaire by the AMLA data collection templates.

Sources for this lesson

Every instrument this lesson is built from, linked to its official text

The two circular letters are the instruments that deployed the AMLA data collection templates in place of the usual questionnaire. Circular CSSF 26/914 of 25 June 2026 is the eligibility exercise for direct supervision by AMLA, run against the criteria in article 12(1) of Regulation (EU) 2024/1620: a credit institution or financial institution, or a group of them, operating in at least six Member States including the home Member State, through establishments or under the freedom to provide services. Article 13(1) then selects from that population those whose residual risk profile is classified as high, and article 13(2) and recital 91 set the first selection at up to forty entities for the Union. Article 13(4) is the timetable: the first selection process commences by 1 July 2027, concludes within six months, the list is published, and direct supervision commences six months after publication. Article 77(1) levies the annual supervisory fee on selected entities and on non-selected entities meeting the article 12(1) criteria. The circular letter of 17 March 2026 is published on the CSSF site under 18 March 2026.

The rest of Module 6

Module 6. Reporting and supervision

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