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AML & Financial Services Regulatory

Luxembourg fund industry: New mandatory AML/CFT external audit and new reporting requirements

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In brief

On 22 December 2021, the Commission de Surveillance du Secteur Financier (CSSF) published three circulars to improve the risk-based supervision of the CSSF, both for anti-money laundering and countering the financing of terrorism (AML/CFT) and prudential purposes.

Circular 21/788 introduces a mandatory external AML/CFT audit for IFMs while Circular 21/789 and Circular 21/790 introduce new reporting requirements for (i) all authorized IFMs, SIAGs and FIAAGs and (ii) UCITS and UCIs subject to part II of the UCI Law, and SIFs and SICARs respectively.

Click here to read our full alert. 

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Author

Laurent Fessmann is co-head of the Banking & Finance practice of Baker McKenzie's Luxembourg office. He has more than 25 years experience in business law and started his career in 1996 as in-house counsel in a French CAC40 listed company, where he worked intensively on LBO transactions, capital markets and corporate law matters. He founded his own firm in August 2009 and established the Baker McKenzie Luxembourg office one year later.

Author

Catherine Martougin is a partner in the Funds & Asset Management team of the Baker McKenzie Luxembourg office. She has more than 25 years' experience in business law. Prior to joining the Firm, she practiced in elite international law firms in Paris and a leading Luxembourg law firm.

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