Circular CSSF 24/854
Circular CSSF 24/854 was published on 29 February 2024. The purpose of the circular was to provide guidance on the Summary report dedicated to AML/CFT ("SRRC") to be prepared by the ‘’responsable du contrôle’’ ("RC") and submitted to the CSSF by the ‘’responsable du respect’’ ("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.
Scope
Two clarifications have been added to the FAQ on the AML/CFT Summary report on compliance with AML/CFT obligations in accordance with Circular CSSF 24/854, in relation to the scope of the circular.
Change in fund manager
If a Luxembourg investment fund originally managed by a foreign fund manager appoints a Luxembourg-based manager before the SRRC submission deadline, the fund will no longer fall under the scope of Circular 24/854. As a result, the SRRC is no longer required for that fund.
Entity no longer supervised by the CSSF
An entity that is removed from the CSSF’s list of supervised entities prior to the SRRC submission deadline is not required to submit the SRRC, even if it was within scope during the previous reporting period.
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