You will never find time for anything. If you want time, you must make it.
We cannot say we were taken by surprise as on 22 December 2021 CSSF published Circulars 21/788, 21/789 and 21/790 to enhance the prudential supervision of the Investment Fund Managers (IFM) and Investment Funds, including AML/CTF as there were enough rumors and discussions. We cannot say that deadlines for SAQ or External Report filings were too tight, and we cannot claim CISERO is difficult to use… But oh boy was it a painful exercise!
On 22 July 2022 the CSSF Published a press release providing clarifications to regulated UCIs and the entities involved in their functioning (e.g. investment fund managers, other service providers) in relation to the organization of the operational processes to be carried out in the CISERO module for the completion of the SAQ and the submission of the reports applicable to those regulated UCIs to the CSSF.
CSSF reminds about the responsibility of the management (dirigeants) for the content of the SAQ, adequate organisational processes and the filing in CISERO of the reports (including the SR and ML), but also clarifies that dirigeants can rely on the support of the service providers. Here it is important to mention that regulated UCIs regardless weather or not the IFM was appointed are allowed to appoint a service provider for completion of the SAQ in the CISERO module and/or the submission of the reports to the CSSF.
How FUND AML Can help?
FUND AML subject matter experts can help you design and implement your business strategy in light of the evolution of regulatory frameworks and market trends.
Our key services include:
- assessment and guidance with updating compliance control framework and policies (inkl. AML and KYA);
- gathering of all necessary information and completing the SAQ;
- submission of the SAQ on CISERO;
- assistance, guidance and project management for SR including AML/KYA;
- Workshops and training.
