“Have no fear of perfection – you’ll never reach it” – Salvador Dali
Sometimes the perfection is not reachable indeed, but not in case of building your governance framework and appointing RR and RC as this is much easier as you think.
Each market participant independent from its regulatory status as requested to comply with the requirements of the AML Law 2004 which requests that AIFM complies with the regulatory requirement to appoint a compliance office “at appropriate hierarchical level”. The CCSF – as well as AED – makes a clear and explicit statement with respect to the appointment of RR (responsable du respect des obligations) and RC (responsable du contrôle du respect des obligations) irrespective of the size of an entity.
So lets have a look at the RR and RC responsibilities
We will be happy to guide you and define required governance structure concerning your AML/CFT obligations to appoint RR and RC.