Circular CSSF 24/854  
Guidelines for the collective  
investment sector on the  
AML/CFT Summary Report RC  
(“SRRC”)  
Circular CSSF 24/854  
Guidelines for the collective investment sector on the AML/CFT  
Summary Report RC (“SRRC”)  
To all Luxembourg investment fund managers including registered AIFMs, Luxembourg branches of  
foreign investment fund managers and all Luxembourg investment funds supervised by the CSSF  
for AML/CFT purposes.  
Luxembourg, 29 February 2024  
Ladies and Gentlemen,  
The purpose of this circular is to provide guidance on the Summary report dedicated to AML/CFT  
(hereafter the “SRRC”) to be prepared by the “Responsable du Contrôle” (hereafter the “RC”) and  
submitted to the CSSF by the “Responsable du Respect” (hereafter the “RR”) in accordance with  
Article 42(7) of CSSF Regulation No 12-02 of 14 December 2012 on the fight against money  
laundering and terrorist financing, as amended (hereafter “RCSSF 12-02”).  
The new SRRC template is taking into account the existing market practices and shall be read without  
prejudice of any other AML/CFT requirements applicable to the entities in scope (e.g. EBA Guidelines,  
etc.).  
It focuses on key data points relevant for the CSSF’s supervision regarding the fight against money  
laundering and countering the financing of terrorism (“AML/CFT”) and is in line with its strategy of  
digitalisation and data driven supervision.  
1. Scope  
The submission of the SRRC referred to in Article 42(7) of RCSSF 12-02 applies to all Luxembourg  
investment fund managers (“IFMs”), including registered alternative investment fund managers  
(“AIFMs”), Luxembourg branches of foreign investment fund managers and Luxembourg investment  
funds supervised by the CSSF for AML/CFT purposes.  
Any such professional is hereafter referred to as “supervised entity in scope”, except those concerned  
by point 2.  
2. Exclusion from scope  
In accordance with Article 42(7) of RCSSF 12-02, the submission to the CSSF of the SRRC is waived  
for “Luxembourg investment funds which designated a Luxembourg management company  
submitting this annual report1.”  
Consequently, these funds do not fall within the scope of this circular.  
1
Excerpt from Article 42(7) of RCSSF 12-02.  
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3. Reporting to the CSSF  
The SRRC must be exclusively submitted via eDesk by the supervised entity in scope. No other form  
of submission will be accepted.  
The requirements to access to the eDesk platform are detailed in Circular CSSF 19/721.  
A user guide for the SRRC is made available to the supervised entity in scope on the eDesk platform.  
The SRRC shall be submitted by the “Responsable du Respect” (i.e. the person responsible for  
compliance with the AML/CFT professional obligations at the level of the authorised management or  
Board of Directors)2, on an annual basis, within five months after the closing of the annual accounts  
of the supervised entity in scope.  
The RR can delegate the technical submission of the SRRC to another person, however, the RR shall  
remain ultimately responsible for the submission.  
Only for the closing ending on 31 December 2023, an extension of two extra months is granted for  
the submission.  
4. Final Provisions  
The provisions of this circular have to be complied with for the financial years ending on or after 31  
December 2023.  
Depending on the AML/CFT legal and regulatory changes, as well as on the needs of the AML/CFT  
supervision by the CSSF, the content of the eDesk template for the SRRC may be adapted in  
subsequent years.  
Claude WAMPACH  
Marco ZWICK  
Jean-Pierre FABER  
Director  
Director  
Director  
Françoise KAUTHEN  
Director  
Claude MARX  
Director General  
2 A technical delegation to an eDesk user linked to the entity and having been assigned with the role of “AML/CFT  
responsible” in the eDesk platform, is permissible to the extent that such delegation is documented in writing  
and made available to the CSSF upon demand.  
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