Following CSSF Regulation 12-02, Luxembourg Funds are required to appoint:

• (i) A person among the members of their management bodies to be in charge of compliance with the applicable professional obligations in the fight against money laundering and terrorist financing (the “Responsable du respect des obligations” or “RR”;

• (ii) A Compliance Officer at the appropriate hierarchical level (the “Responsable du contrôle du respect des obligations” or “RC”).

Who does this apply to?

• Regulated funds

• Unregulated funds managed by an AIFM

• Unregulated funds (in line with AED requirements where applicable)

Eligibility for these roles

• The RR/RC must have sufficient AML/CFT knowledge and expertise with regards to the laws and regulations applicable in Luxembourg and demonstrate this upon request (training, work experience);

• The RR/RC must have sufficient knowledge of the investment and distribution strategies of the funds/about the services offered by the Investment Fund Manager;

• The RR/RC must be available without delay upon request by the Luxembourg AML/CFT competent authorities;

• The RC should have access to all internal documents and systems required necessary for performing its tasks. This condition is particularly relevant where the RC is not present in Luxembourg on an ongoing basis.

Our services

• Providing experienced members to act as RR and/or RC/AML-CFT Compliance Officer for your Investment Fund: SIFs, SICARs, RAIFs, other unregulated AIFs.

Performing AML/CFT tasks as RR:

• Validate compliance with the applicable AML/CFT rules;

• Regulations, including processes and policies;

• Review any regular and annual reporting provided by the RC;

• To be reachable for any contact by the Luxembourg AML/CFT competent authorities.

Performing AML/CFT tasks as RC:

• Reviewing and updating the AML/CFT policy of the funds if needed;

• Annual AML/CFT risk assessment of the funds;

• Periodic and ad-hoc written reports to the management/board of directors;

• Registration with GoAML (FIU), report suspicious transactions or activities to the RR, and if necessary, to the FIU;

• Annual AML/CFT training for relevant persons at the funds;

• Quarterly/ Annually “RC” reports;

• Central contact for AML/CFT purposes with the Luxembourg authorities;

• To be available without delay upon request by the Luxembourg AML/CFT competent authorities.