Communication regarding the update of the eDesk procedure: AML/CFT Market Entry Form
CSSF
Aiming at collecting standardised key information in relation to money laundering and terrorist financing risks (“ML/FT risks”), the Market Entry Form (“MEF”) must be submitted by Funds (to be) authorised (including ELTIFs regardless of the type of AIF) and Investment Fund Managers (“IFMs”) (to be) authorised or registered that are supervised for AML/CFT purposes by the CSSF.
Solely the following requests trigger a submission of an AML/CFT MEF:
Fund: upon authorisation (including authorisation/registration under a European label, i.e. ELTIF, EuSEF or EuVECA)
Fund: adding (a) sub-fund(s) only if at least one of the following events are triggered by the new sub-fund(s): – new initiator(s); – new founder(s); – sub-fund(s) designed for a limited number of investors; – additional/new type of investments
ELTIF (other than Part II UCI, SIF, SICAR): upon notification of (a) new (change of) manager(s)/director(s), “RR” or “RC”
IFM: upon authorisation
IFM: modification of qualified shareholding
IFM: upon registration as an AIFM pursuant to Article 3 of the AIFM Law.
These requests are defined as “parent requests” and the Market Entry Form must be submitted in parallel.
The AML/CFT MEF must be initiated and submitted by:
the compliance officer in charge of the control of compliance with the professional obligations1 (“responsable du contrôle du respect des obligations professionnelles” (“RC”)) of the Fund or the IFM, or
the person responsible for compliance with the professional obligations2 (“responsable du respect des obligations professionnelles” (“RR”)) of the Fund or the IFM.
However, the completion of the AML/CFT MEF, may be assigned within eDesk to another employee of the entity or third party, while bearing in mind that the ultimate responsibility for the adequate completion of the form remains with the “RC” and “RR”.
Please consider the parent requests that trigger the submission of an AML/CFT MEF and submit such a Form ONLY in case of a triggering event.
Please note that since 23 September 2025, information on the sections Portfolio Manager(s) and Investment Advisor(s) is no longer requested by the CSSF in the AML/CFT MEF for authorised and registered IFMs and these sections have been removed.
As from 23 September 2025, these sections have been automatically removed from any MEF with status Draft or Reopened (including in the MEF submitted before this date) even where the sections had been completed beforehand.
These sections will only remain in the MEF with status Closed before this date.
The CSSF would also like to remind the persons responsible for completion of the AML/CFT MEF that a regular monitoring must be carried out on an AML/CFT MEF that has been initiated (i.e. is in draft status) but has not been submitted after more than one year. The CSSF expects these to either be completed and submitted or deleted.
Please consult the user guide on eDesk Portal for more general application details and the FAQ for more specific questions.
All information related to the creation of user account(s) is detailed in the lower section of the eDesk Portal.