On 25 November 2019, the CSSF issued an FAQ on persons involved in AML/CTF for a
Luxembourg fund or investment fund manager
("IFM") supervised by the CSSF for
AML/CTF purposes. The aim of the FAQ, which is currently composed
of two questions, is to share the CSSF's interpretation of
Article 4(1) of the Law of 12 November 2004 on the fight against
money laundering and terrorist financing, as amended
("AML Law").
While the FAQ is only applicable to entities subject to the
CSSF's supervision, unregulated funds may nevertheless wish to
take its provisions into account since they are subject to the AML
Law as well.
In Question 1 of its FAQ, the CSSF recalls that in its view,
every Luxembourg fund and IFM subject to AML/CTF supervision is
legally required to appoint:
