Annual AML return deadlines — DFSA, FSRA and CSSF
Deadlines: the full filing calendar · the regulation library · practical guides
Every regulated manager files an annual AML return. Almost nothing about it is standard. The reporting year, the portal and the deadline all differ from one regulator to the next. Each jurisdiction sets its own date. The table below lists every one we hold, with the date its own regulator publishes and a link to it.
What is the annual AML return?
An annual AML return is a yearly report on how a firm manages money-laundering and terrorist-financing risk. It covers customer checks, monitoring, suspicious-activity reporting and governance. It is a supervisory return, filed with the financial regulator, not the tax authority (DFSA AML return rule).
What is in the report
The return reports the firm's client base and risk ratings, the volume of activity monitored, and the number of suspicious reports made. It also confirms that the reporting officer's own report reached the board. The regulator uses it to target supervision.
Who files, who prepares, who receives
The regulated firm files. For a fund structure that is the manager, or the fund itself where it is licensed. The money-laundering reporting officer usually owns it. It goes to the conduct regulator: the DFSA in the DIFC, the FSRA in ADGM, the CSSF in Luxembourg.
This page carries 3 confirmed deadlines for the annual AML return, each with the date its own regulator publishes.
When it is due
| Jurisdiction | Obligation | Due | Reporting period | Who files | Files with | Extension | Source |
|---|---|---|---|---|---|---|---|
| ADGM (Abu Dhabi) | FSRA Annual AML Return (covers the preceding calendar year), via FSRA Connect | 30 April 2027 (prior year: 30 April 2026) | the preceding calendar year | the AIFM or management company | FSRA | — | ADGM FSRA Anti-Money Laundering and Sanctions Rulebook (AML) 4.6.1 — Annual AML Return · calendar |
| DIFC (Dubai) | DFSA Annual AML Return via the DFSA electronic portal (reporting period 1 Aug previous year – 31 Jul) | 30 September 2027 (prior year: 30 September 2026) | 1 August to 31 July | the AIFM or management company | DFSA | — | DFSA Rulebook AML 14.5.1 — Annual AML Return · calendar |
| Luxembourg | CSSF SRRC — AML/CFT summary report of the RC, within 5 months of the financial year-end | within 5 months of the financial year-end | set by the rule | the AIFM or management company | CSSF | — | CSSF Circular 24/854 — AML/CFT summary report RC (SRRC), FAQ · calendar |
Common mistakes
The reporting periods rarely align across jurisdictions. ADGM works to the calendar year while the DFSA runs an August-to-July year, so a group licensed in both files two returns on two separate timetables. The annual return is also distinct from the reporting officer's own internal report to the board, even though the one feeds the other. And a clean year is still a reporting year. A regulator reads a run of no reports as information about the firm's monitoring, not as a reason to skip the filing.
Questions this page answers
When is the DIFC annual AML return due?
The DFSA return is due 30 September 2027 (prior year: 30 September 2026). It covers the year to the end of July, filed through the DFSA's electronic portal.
When is the ADGM annual AML return due?
The FSRA return is due 30 April 2027 (prior year: 30 April 2026), covering the preceding calendar year. It is filed via FSRA Connect, a different date and period from the DIFC.
When is the Luxembourg AML summary report due?
The CSSF summary report is due within 5 months of the financial year-end. It is the control officer's AML/CFT summary report, submitted via eDesk under CSSF Circular 24/854.
Does a manager with no suspicious activity still file?
Yes. A nil return is still a return. Regulators read a year of no reports as information about the firm's monitoring, not a reason to skip the filing.