RR/RC Services

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Following the CSSF’s FAQ on 25 November 2019, 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 (to be considered)

Eligibility for these roles

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

  • The RR/RC are 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;

  • 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 Company if needed;

  • Annual AML/CFT risk assessment of the company;

  • 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 company;

  • 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.

Engelwood legal entities are truly independent providers of corporate & fund services, asset management, financial engineering/advisory, tax and related services, able to leverage on the existing expertise of the relevant Engelwood entities. Our own offices and dedicated partners network are offering to deal with cross border solutions in several jurisdictions. Each of the entities is member firm of the Engelwood network of independent members firms affiliated with Engelwood Holding, a Luxembourg entity, each member firm of which is a separate legal entity. All rights reserved.

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Engelwood refers to one or more of Engelwood Holding (“EH”), its global network of member firms, and their related entities (collectively, the “Engelwood Network”). EG and each of its member firms and related entities are legally separate and independent entities, which cannot bind each other in respect of third parties. EH and each EH member firm and related entity is liable only for its own business, acts and omissions, and not those of each other. EH does not provide services to clients.

The content of this website and any reference to any brochure and other publications are disclosed for information purposes only. They do not constitute any offer. Nothing in this website and other publications should be relied upon as constituting legal or professional advice. Neither the member firms of the Engelwood Network nor any of its shareholders, affiliates, directors, managers or employees accept any responsibility whatsoever for any loss occasioned to any person no matter howsoever caused or arising as a result, or in consequence, of action taken in reliance on any of the content of this website. No representations, warranties or undertakings (express or implied) are given as to the accuracy or completeness of the information in this communication, and none of EH, its member firms, related entities, shareholders, directors, officers, or employees shall be liable or responsible for any loss or damage whatsoever arising directly or indirectly in connection with any person relying on this communication. EH and each of its member firms, and their related entities, are legally separate and independent entities.

ENGELWOOD® is a registered trade mark

Engelwood refers to one or more of Engelwood Holding (“EH”), its global network of member firms, and their related entities (collectively, the “Engelwood Network”). EG and each of its member firms and related entities are legally separate and independent entities, which cannot bind each other in respect of third parties. EH and each EH member firm and related entity is liable only for its own business, acts and omissions, and not those of each other. EH does not provide services to clients.

The content of this website and any reference to any brochure and other publications are disclosed for information purposes only. They do not constitute any offer. Nothing in this website and other publications should be relied upon as constituting legal or professional advice. Neither the member firms of the Engelwood Network nor any of its shareholders, affiliates, directors, managers or employees accept any responsibility whatsoever for any loss occasioned to any person no matter howsoever caused or arising as a result, or in consequence, of action taken in reliance on any of the content of this website. No representations, warranties or undertakings (express or implied) are given as to the accuracy or completeness of the information in this communication, and none of EH, its member firms, related entities, shareholders, directors, officers, or employees shall be liable or responsible for any loss or damage whatsoever arising directly or indirectly in connection with any person relying on this communication. EH and each of its member firms, and their related entities, are legally separate and independent entities.

ENGELWOOD® is a registered trade mark