In accordance with Article 4 of the AML/CFT Law, every IFM must designate an AML/CFT Compliance Officer at senior management level (AML/CFT compliance officer at the management level) as well as an AML/CFT Compliance Officer. As regards the designation of an AML/CFT Compliance Officer referred to in Article 4(1)(a) of the AML/CFT Law, the IFM must take into account the size and nature of its activities.

The AML/CFT compliance officer at the management level must draw up a summary report on compliance with AML/CFT professional obligations at least once a year. This report must be submitted for approval to the management body/governing body of the IFM. Once a year, this report covering the preceding year must be sent to the CSSF within five months following the end of the IFM’s financial year.
Unterforen: Summary Report RC (SRRC)

It should be borne in mind that the internal audit function must assess independently, inter alia, the ML/TF risk management models and report to the senior management and to the management body/governing body by submitting them at least once a year a summary report on the compliance with the AML/CFT obligations. The internal audit must show diligence by ensuring that its recommendations or corrective measures are effectively carried out.

Obligations applicable to the IFM according to the manner in which the relationship with marketing intermediaries and the function of registrar agent is organised