Background
With circular 18/698 of 23 August 2018 on (i) the authorisation
and organisation of Luxembourg investment fund managers, and (ii)
provisions on combatting money laundering and terrorist financing
applicable to investment fund managers and entities carrying out
the function of registrar agent (the Circular),
the Commission de Surveillance du Secteur Financier
(CSSF) provides clarifications and, to some
extent, introduces new requirements aimed at increasing
transparency in the fight against money laundering and terrorist
financing.
This briefing focuses particularly on the anti-money laundering
and combating the financing of terrorism (AML/CFT)
provisions set out in sub-chapter 5.4 of the Circular.