News and developments
CSSF (Luxembourg) publishes Circular and FAQs on the AML/CFT Summary Report RC
issued Circular CSSF 24/854 (the “Circular”) titled “Guidelines for the collective investment sector on the AML/CFT Summary Report RC (“SRRC”) and applicable FAQs on the SRRC.
The Circular provides guidance on the SRRC which is to be prepared by the “Responsable du Contrôle” (the “RC”) and submitted to the CSSF by the “Responsable du Respect” (the “RR”) in accordance with Article 42(7) of CSSF Regulation No 12-02 of 14 December 2012 on the fight against money laundering and terrorist financing, as amended (the “RCSSF 12-02”).
Scope
The Circular provides that the submission of the SRRC in terms of Article 42(7) of RCSSF 12-02 applies to:
Author: Neil Bezzina
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- All Luxembourg Investment Fund Managers – IFMs (including registered alternative investment fund managers – AIFMs);
- Luxembourg branches of Foreign Investment Fund Managers; and
- Luxembourg Investment Funds supervised by the CSSF for AML/CFT Purposes.
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- AML/CFT findings identified by the RC;
- AML/CFT findings identified by the internal audit report presented to the board (if applicable);
- AML/CFT findings identified by the Approved Statutory Auditor as reported in the Management Letter reported to the board; or
- AML/CFT findings reported by the CSSF in a letter to the entity.
Author: Neil Bezzina