CSSF ¦ Update of the eDesk Procedure: AML/CFT Market Entry Form (Funds and IFMs)

CSSF Updates AML/CFT Market Entry Form: What Funds and IFMs Need to Know

The Commission de Surveillance du Secteur Financier (CSSF) has introduced targeted updates to the AML/CFT Market Entry Form (MEF) to streamline the collection of standardized information on money laundering and terrorist financing (ML/FT) risks. The MEF remains mandatory for Funds that are or will be authorised (including ELTIFs, regardless of their AIF type) and for Investment Fund Managers (IFMs) that are or will be authorised or registered and supervised by the CSSF for AML/CFT purposes. The changes refine when the form must be filed and what information is required, while reinforcing expectations around governance and timely submission.

When a Submission Is Required

The CSSF has reiterated that the MEF must be submitted only in connection with specific “parent requests”.

• For Funds, submission is triggered upon authorisation, including authorisation or registration under a European label such as ELTIF, EuSEF, or EuVECA.
• Funds must also submit when adding sub-funds, but only if the new sub-fund introduces a new initiator, a new founder, is designed for a limited number of investors, or brings an additional or new type of investment.
• For ELTIFs that are not Part II UCIs, SIFs, or SICARs, a submission is required upon notification of a change of manager(s) or director(s), or changes to the “RR” or “RC”.
• For IFMs, a submission is required upon authorisation, where there is a modification of a qualified shareholding, and upon registration as an AIFM under Article 3 of the AIFM Law.

These parent requests define the perimeter of the obligation, and the MEF must be submitted in parallel with the underlying request.

Bastian Schwind-Wagner_Follow "The CSSF has refined when the AML/CFT Market Entry Form must be submitted and streamlined its content for IFMs by removing Portfolio Manager and Investment Advisor sections as of 23 September 2025. RCs and RRs must ensure timely submission aligned with defined parent requests and proactively close or delete drafts older than one year."

Who Is Responsible for the MEF

Responsibility for initiating and submitting the AML/CFT MEF lies with the “responsable du contrôle du respect des obligations professionnelles” (RC) or the “responsable du respect des obligations professionnelles” (RR) of the Fund or IFM. While these roles can assign completion of the MEF within the eDesk environment to another employee or a third party, the RC and RR retain ultimate accountability for the accuracy and completeness of the submission. This governance structure underscores the CSSF’s expectation that AML/CFT responsibilities remain anchored at the appropriate level of seniority and oversight.

Removal of Portfolio Manager and Investment Advisor Sections

A key change effective 23 September 2025 is the removal of the Portfolio Manager(s) and Investment Advisor(s) sections from the AML/CFT MEF for authorised and registered IFMs. These sections have been automatically stripped out from any MEF that was in Draft or Reopened status as of that date, even if previously completed. They will remain visible only for MEFs that were in Closed status before 23 September 2025. The practical implication is a leaner form for IFMs going forward, and the need to be aware that historical drafts may look different from current templates.

Timeliness and Housekeeping: Drafts Older Than One Year

The CSSF expects proactive monitoring of any MEF initiated but not submitted. Drafts that linger for more than one year should not remain dormant. The expectation is clear: either complete and submit the form or delete it. This is a reminder that AML/CFT oversight includes lifecycle management of regulatory filings, not just initial data entry.

Submitting Only When Triggered

The CSSF emphasizes that firms should submit an AML/CFT MEF only when a triggering parent request applies. This helps avoid unnecessary filings and keeps the focus on events that are material for AML/CFT risk assessment, such as changes in governance, control, investor profile, or investment strategy.

Practical Next Steps

Firms should re-confirm their internal triggers and workflows so that an MEF is prepared and submitted in parallel with any parent request. RCs and RRs should verify that responsibilities are clearly assigned in eDesk, that draft forms are reviewed regularly, and that any legacy drafts older than one year are resolved. Given the removal of the Portfolio Manager and Investment Advisor sections for IFMs, compliance teams should ensure their templates, checklists, and internal guidance are updated to reflect the current form structure.

Where to Find Support

For operational details on how to use the eDesk Portal, firms should consult the user guide. The FAQ provides additional clarity on particular scenarios that may arise during completion and submission. Information on creating user accounts is available in the lower section of the eDesk Portal homepage. These resources support both first-time filers and entities managing changes to authorisations, registrations, or governance.

Bottom Line

The CSSF’s updates tighten alignment between AML/CFT oversight and key lifecycle events of Funds and IFMs, reduce unnecessary data collection for IFMs, and reinforce accountability and timeliness. By calibrating their processes to the defined parent requests, ensuring RC/RR oversight, and cleaning up aged drafts, Funds and IFMs can meet expectations efficiently while maintaining robust AML/CFT governance.

Dive deeper

• CSSF Communiqué ¦ Communication regarding the update of the eDesk procedure: AML/CFT Market Entry Form (Funds and IFMs) ¦ Link