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.
Author
Laurent Fessmann
Laurent Fessmann is a Banking & Finance partner specializing in the formation and structuring of Luxembourg investment funds. He is a former managing partner of the Luxembourg office and the current co-chairman of the Baker McKenzie's Global Funds Steering Committee. He 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. Mr. Fessmann joined a Luxembourg business law firm where he became a partner prior to founding his own law firm in 2009. He is a highly regarded professional and recognized legal professional in Chambers, Legal 500, IFLR notably. He contributes time and knowledge in several market participant industry associations in particular as co-chairman of the ABBL/ALFI depositary forum working groups, the European Public Real Estate Association, the Luxembourg Private Equity Association and the Association of Global Custodians. He is also a regulator at fund conferences such as ALFI, IBCI and regularly invited to speak on internal or bank seminars.
