On 25 August 2022, the Commission de Surveillance du Secteur Financier (CSSF) published its updated FAQ on the AML/CFT RC Report for supervised Luxembourg Investment Funds and Luxembourg Investment Fund Managers, in relation to the completion and transmission of the AML/CFT compliance officer’s summary report (AML/CFT RC report).

Each entity supervised for AML/CFT purposes, must prepare an AML/CFT RC report in order to present it to the entity’s management board.

The following entities are required to submit the AML/CFT RC report to the CSSF:

• Luxembourg Investment Fund Managers (authorised and registered)
• Luxembourg Investment Funds regulated by the CSSF which have appointed a foreign Investment Fund Manager
• Luxembourg Investment Funds regulated by the CSSF which have not appointed an Investment Fund Manager (self-managed funds)

As a reminder, reserved alternative investment funds (RAIFs) are not supervised by the CSSF. RAIFs are under the supervision of the Administration de l’enregistrement, des domains et de la TVA (AED), Luxembourg’s Registration Duties, Estates and VAT Authority which recently published a guide on professional AML/CFT obligations and RAIFs’ regulatory obligations.

The guide (in French) can be found here.