New CRF guidelines: deadlines to answer the CRF and freezing of a fund's investor register

On 1 September 2026, the CRF, Luxembourg's financial intelligence unit, published its "Guidelines on the cooperation with the FIU". They replace its guidelines of 6 January 2026 on suspicious operations reports and on freezing orders. Reports still go to the CRF exclusively through goAML.

Five business days to answer an information request

The CRF applies, effective immediately, the deadlines of Article 69(1) of the AML Regulation (AMLR) to its information requests, even though the regulation itself only applies from 10 July 2027. A reporting entity must reply within five business days, and within 24 hours when the request is highly urgent. In specific and duly justified cases, the CRF may set less than 24 hours. The AML/CFT law of 12 November 2004 requires a reply "without delay". Replies are submitted on goAML Web, with the RIRA and/or RIRT forms.

Freezing orders: a fund's investor register can be frozen

A CRF freezing order may cover the register of investors in a fund or sub-fund. It is not limited in time. The CRF may withdraw it at any time, and it can be challenged in court. While it is in effect, the reporting entity may not terminate the business relationship.

Who is on the front line in a fund

For a RAIF, the RC usually files suspicious transaction reports via goAML, with the RR as fallback. In our view, they should expect the CRF's questions too, often about investors whose data sits with the transfer agent. For the RC's role and deliverables, see our guide to the Responsable du Contrôle in Luxembourg.

Do not tip off

Reporting entities must not disclose the existence of a suspicious operations report or of a CRF information request; the exceptions are narrow, for example disclosure to the supervisory authorities.

What we recommend to RCs

• Update each fund's AML/CFT procedure with the new deadlines, and name who answers the CRF when the RC is away.
• Set standing turnaround times for data requests in the transfer agent's service agreement, so that an urgent request never has to be explained.
• In our experience, the RC and the transfer agent usually work together, but if reports to the authorities are not coordinated beforehand, either of them may receive a CRF freezing order.
• Agree with the transfer agent now, at procedure level and never case by case, who receives what and how a freeze on the investor register would be applied, keeping it confidential from the investor and minding tipping-off.
• Replace any reference to the previous CRF guidelines in procedures and training material.