CSSF guidance on persons involved in AML/CFT for Luxembourg regulated funds and investment fund managers
16 Dec 2019
The CSSF has recently provided helpful guidance to Luxembourg investment fund managers (Chapter 15 & 16; AIFMs and registered AIFMs) and regulated funds (SIFS, Part II, SICAV and UCITS) including regulated funds that do not qualify as AIFs (such as family funds) on how these entities should meet their obligations under Article 4(1) of the law of 12 November 2004 (adequate internal management requirements). This article of the law requires the appointment of two AML/CFT functions: (1) for compliance (responsable du respect des obligations, hereafter theRR) at the management level and (2) a control function (responsable du contrôle du respect des obligations, hereinafter theRC), both roles cannot be fulfilled by the same person.
The CSSF FAQ can be found here.
A summary of the RR and RC functions can be found here.