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pc nid 91086 Mar 05, 2026 tojuri@vixio.com Luxembourg Administrative Enforcement Actions - CSSF horizon scanning
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Luxembourg's Financial Regulator Imposes Fine on Investment Firm for Corporate Governance Breaches

On 8 October 2025, the Commission de Surveillance du Secteur Financier (CSSF) imposed an administrative fine of EUR 223,000 on an investment firm for non-compliance with professional obligations related to corporate governance. The CSSF identified breaches across multiple regulatory provisions of the amended Law of 5 April 1993 on the financial sector, including Articles 14, 17, 19, 40, and 59, as well as Article 17(1a). The violations were detected between 2019 and 2024 through on-site inspections conducted between 2022 and 2024, information from 2023 closing documents, and responses to an injunction letter dated 18 February 2020. Key areas of non-compliance included: inadequate central administration arrangements in Luxembourg, with members of the authorised management and the Chief Investment Officer not permanently residing in Luxembourg; excessive outsourcing of portfolio management activities outside Luxembourg; deficiencies in internal control functions, internal audit, and external audit arrangements; and inadequate fit and proper assessment of the Board of Directors. The CSSF determined the fine amount by considering the severity and number of breaches, the entity's acknowledgment of findings, and its provision of a general action plan. The entity has since implemented substantial remediation measures, including changes to management body composition and control functions. The CSSF's decision was made pursuant to Articles 63-2a(1) to 63-2a(4), 63-2b, and 63-4 of the amended Law of 5 April 1993, with reference to Circular CSSF 20/758 as amended by Circulars CSSF 21/785 and CSSF 22/806 on central administration, internal governance, and risk management. REFERENCES: Commission de Surveillance du Secteur Financier (CSSF) Administrative Decision, 8 October 2025

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Luxembourg Commission de Surveillance du Secteur Financier Imposes €223,000 Fine on an Investment Firm for Corporate Governance Breaches

In a decision dated October 8, 2025, the Commission de Surveillance du Secteur Financier (CSSF) imposed an administrative fine of EUR 223,000 on an investment firm for non-compliance with its professional obligations regarding corporate governance. The CSSF identified breaches across multiple regulatory provisions of the amended Law of 5 April 1993 on the financial sector , including Articles 14(2), 17(1)-(1a), 19(3), 40, and 59. The violations were detected between 2019 and 2024 through on-site inspections conducted between 2022 and 2024, information from 2023 closing documents, and responses to an injunction letter dated 18 February 2020. The CSSF identified cases of non-compliance with professional obligations relating to internal governance arrangements in the following areas: Inadequate central administration arrangements; The firm did not comply with the condition of permanent presence in Luxembourg, as neither members of the authorised management nor the Chief Investment Officer reside permanently in Luxembourg. Excessive outsourcing of portfolio management activities outside Luxembourg. The firm did not comply with the condition of permanent presence in Luxembourg, as neither members of the authorised management nor the Chief Investment Officer reside permanently in Luxembourg. Excessive outsourcing of portfolio management activities outside Luxembourg. Shortcomings in the internal control framework; deficiencies in internal control functions that jeopardise the firm's sound and prudent management. Deficiencies in the internal audit and external audit arrangements; Inadequate fit and proper assessment of the Board of Directors. deficiencies in internal control functions that jeopardise the firm's sound and prudent management. Deficiencies in the internal audit and external audit arrangements; Inadequate fit and proper assessment of the Board of Directors.