Regulatory Alerts2021-12-22
CSSF Guidelines for the Collective Investment Sector on the AML/CFT External Report
The Luxembourg Commission de Surveillance du Secteur Financier (CSSF) mandates all supervised investment funds and fund managers to submit an annual Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) external report prepared by an approved statutory auditor. The report requires the auditor to verify responses to the CSSF’s annual online survey and conduct risk-based sample testing, with both parties permitted to comment on the findings before submission through the eDesk platform. Supervised entities must file this report within six months of their annual accounts closing for financial years ending on or after 31 December 2021, while exempt funds still require their auditors to perform prescribed AML work and report significant deficiencies.