New ML/TF risk assessment questionnaire for life insurance intermediaries

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The CAA Circular Letter 23/3 on the harmonised quantitative money laundering and terrorist financing risk exposure assessment questionnaire addresses the relevant insurance intermediaries.

On 7 February 2023, the Commissariat aux Assurances (“CAA”) published Circular Letter 23/3 on the harmonised quantitative money laundering and terrorist financing (“ML/TF”) risk exposure assessment questionnaire addressed to relevant insurance intermediaries (“Circular 23/3”).

1. Background

Circular 23/3 aims to extend the quantitative ML/TF risk exposure assessment questionnaire, introduced in 2018 under CAA Circular Letter 18/9 for life insurance companies, to relevant insurance intermediaries, by adapting it to the specificities of insurance intermediation.

Accordingly, relevant intermediaries will now also be required to complete a dedicated questionnaire for the purposes of evaluating their ML/TF risk exposure for certain categories of distributed life insurance policies (“Quantitative Questionnaire”).

2. Scope of application

Circular 23/3 applies to:

(“Relevant Intermediaries“);

which are distributing or have distributed:


3. Aim

The aims of Circular 23/3 are to:

4. Key requirements

a. Completion of the Quantitative Questionnaire

The Quantitative Questionnaire must be completed for any:

The risk scores for each Contract must be archived electronically and be accessible, to ensure a reliable audit trail.

b. Data collection

Relevant Intermediaries must additionally provide the CAA with data on the following on an annual basis:


c. Impact on internal procedures

Relevant Intermediaries are invited to document the operational arrangements associated with the implementation of Circular 23/3 in their internal procedures, including:





5. Timeline

The Quantitative Questionnaire must be used as of 1 July 2023.

Relevant Intermediaries must submit the data collected to the CAA by 31 January each year.


Our experts Pierre-Michaël de Waersegger, Samantha Marx, Emmanuelle Mousel and Sandrine Périot are at your disposal should you have any questions.

If you require any assistance or advice regarding the rules and requirements governing ML/TF exposure for insurance companies and/or intermediaries, please contact our insurance experts.

Our dedicated Financial crime – AML/CFT team has also developed a dedicated service offering for providing comprehensive legal and operational assistance with the ever-growing AML/CTF compliance challenges.


Read Circular 23/3 (French only) here_

Download the press release

Luxembourg Newsflash – New MLTF risk assessment questionnaire for life insurance intermediaries

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