FAQ on the AML/CFT Summary Report RC (“SRRC”) on compliance with AML/CFT obligations in accordance with Circular CSSF 24/854
CSSF
Scope & Exemptions
Entities within scope:
All Luxembourg investment fund managers (including AIFMs),
Luxembourg branches of foreign fund managers,
Luxembourg investment funds supervised for AML/CFT purposes.
Exemptions:
Luxembourg investment funds that have appointed a Luxembourg management company to submit the SRRC are exempt—no direct submission is required.
Funds managed by a foreign manager but also appointing a Luxembourg IFM providing UCI administration services are similarly exempt.
If, by the submission date, a fund is no longer under CSSF supervision, the requirement to submit the SRRC no longer applies.
Key Transitions & Clarifications
The SRRC replaces the previous RC Report which was historically required within five months of the financial year-end.
The annual AML/CFT Risk Assessment, previously submitted separately, is now fully integrated within the SRRC.
What Must Be Reported in the SRRC
The “AML/CFT Findings” section must include all relevant findings—both ongoing (open) and resolved (closed)—from:
The RC’s own oversight,
Internal audit findings presented to the board,
Statutory auditors (via management letters),
CSSF-identified issues communicated in writing.
The term "sample testing" refers to document-based reviews, such as KYC or screening evidence. SRRC must include details on the number and scope of due diligence files reviewed during the period.
Submission Process
The SRRC must be submitted annually via the eDesk platform by the RR. Only this channel is accepted—no alternative methods.
Submission must occur within five months of the fund’s year-end, though a two-month extension was granted for 31 December 2023 closings.
https://www.cssf.lu/wp-content/uploads/FAQ-on-the-AML-CFT-summary-report-RC-SRRC.pdf