CSSF AML/CFT reporting tool: first reporting period approaches

Following the publication of three circular letters [1] in December 2021 introducing new prudential and AML/CFT reporting requirements, the Luxembourg Financial Sector Supervisory Authority (the CSSF) has made available a new module titled “Collective Investment Sector Reporting Tool” (CISERO) on their eDesk platform.

This module, accessible since January for preparation and submission of AML/CFT external reports under Circular 21/788 and IFM reports under Circular 21/789, has been made available, as of 31 March 2022 in order to comply with the requirements set out in Circular 21/790, to regulated UCIs, ie UCITS, UCIs subject to Part II of the Law of 17 December 2010 (UCIs Part II), Specialised Investment Funds (SIFs) and Investment Companies in Risk Capital (SICARs).

As per our previous briefing (which can be accessed through the above link), reports to be submitted via CISERO are the self-assessment questionnaire (SAQ), the separate report (SR) and the management letter (ML).

The CSSF has highlighted that the reports available from the outset are: "the SAQ, the SR (only for UCITS and UCIs Part II) and the ML for the regulated UCIs with a financial year ending between 30 June 2022 and 30 November 2022". Information on the availability of these reports for subsequent financial years will be provided in a dedicated CISERO FAQ.

A specific procedure for submitting the information regulated UCIs have to provide to the CSSF, as per Circular 21/790, is to be respected - in cases where an approved statutory auditor issues a modified audit opinion, the fund's management has to transmit a signed letter, accompanied by required information and supporting documentation to the email address: opc_sp_courrier@cssf.lu

If you have any further questions, please contact a member of our Luxembourg Investment Funds team.

[1] Circulars CSSF 21/788, 21/789 and 21/790 of 22 December 2021

About Ogier

Ogier is a professional services firm with the knowledge and expertise to handle the most demanding and complex transactions and provide expert, efficient and cost-effective services to all our clients. We regularly win awards for the quality of our client service, our work and our people.

Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

Regulatory information can be found under Legal Notice