- 29/02/2024 : CSSF circular 24/854 is published
- 31/07/2024 : 31/12/2023 SRRC (formalised with the new template) shall be transmitted to the CSSF
The CSSF Circular 24/854 introduces an eDesk template of Summary Report of the RC (SRRC) that must be used for the financial years ending on or after December 31, 2023.
The updated SRRC template incorporates current market practices and highlights essential data points critical for the CSSF’s oversight in combating money laundering and terrorism financing.
Scope
CSSF Circular 24/854 applies to :
- Luxembourg Investment Fund Managers (“IFMs”);
- Luxembourg Investment Funds supervised by the CSSF for AML/CFT purposes.
This CSSF Circular is not applicable to Luxembourg Investment Funds which designated a Luxembourg management company submitting the SRRC.
In practice
1. How to submit the SRRC ?
The SRRC is required to be submitted solely through eDesk by the entity under supervision. The CSSF will not accept submissions in any form other than through eDesk.
2. Who shall submit the SRRC ?
The SRRC shall be submitted by the “Responsable du Respect” (RR).
The RR can delegate the technical submission of the SRRC to another person but he remains responsible.
3. When shall the SRRC be submitted ?
On an annual basis, within 5 months after the closing of the annual accounts of the supervised entity.
For the closing ending on 31 December 2023, an extension of two extra months is granted.
Useful Resources
Discover our other publications :
RC Report of RAIFs
The AED has launched a campaign to invite the RC of all RAIFs to communicate their 31/12/2023 summary report before 31/05/2024. The AED has also specified, on its website, the minimal content of this report.
Insights from the CSSF 2024 AML/CTF conference (Specialised PFS)
The 2024 AML/CFT Conference for Specialised PFS offered deep insights into the challenges and best practices in anti-money laundering and counter-terrorist financing.
Circulaire CSSF 24/850
Circulaire applicable aux PSF de support. Nouvelles règles pratiques relatives au rapport descriptif et introduction d’un questionnaire d’auto-évaluation.