- 29/02/2024 CSSF circular 24/854 has been published
- 31/07/2024 31/12/2023 SRRC (formalised with the new template) shall be transmitted to the CSSF
The CSSF Circular 24/854 introduces an eDesk template of Summary Report of the RC (SRRC) that must be used for the financial years ending on or after 31 December 2023.
The updated SRRC template incorporates current market practices and highlights essential data points critical for the CSSF’s oversight in combating money laundering and terrorism financing.
Scope
CSSF Circular 24/854 applies to:
- Luxembourg Investment Fund Managers (IFMs);
- Luxembourg Investment Funds supervised by the CSSF for AML/CFT purposes.
This CSSF Circular is not applicable to Luxembourg Investment Funds which have designated a Luxembourg management company that submits the SRRC.
In practice
1. How to submit the SRRC?
The SRRC is required to be submitted solely via eDesk by the entity under supervision. The CSSF will not accept submissions in any form other than through eDesk.
2. Who shall submit the SRRC?
The SRRC shall be submitted by the “Person Responsible for Compliance”RR).
The RR can delegate the technical submission of the SRRC to another person, but they remain responsible.
3. When shall the SRRC be submitted?
Annually, within 5 months after completion of the annual accounts of the supervised entity.
For the closing end of financial year on 31 December 2023, with a two-month extension is granted.
Useful Resources
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AMLA: the new European authority at the heart of AML/CFT supervision
Scope, governance, KYC due diligence, beneficial ownership, suspicious activity reports, and cash payments: the key contributions of the AMLR.

AMLR: The European regulation to be directly applicable from 10 July 2027
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