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CSSF Circular 12/544 - Towards a risk-based supervision of the “Support PSF"

A new assurance against risks

A new regulation to meet new challenges

CSSF Circular 12/544 - A new assurance against risksSeveral years ago, the status of Support Professionals of the Financial Sector (Support PSF) was created in Luxembourg law in order to guarantee an appropriate level of high- quality organisation in companies offering operational and technical services to financial professionals.

CSSF Circular 12/544 constitutes a new stage in the supervision of Support PSF and optimises this supervision using a risk-based approach.

The new circular seeks to ensure the appropriate management of direct or indirect risks that might impact their professional financial clients.

Support PSFs are therefore faced with a huge challenge and an immediate response is required: they must implement  the first requirement of this new circular – the risk analysis report – by 31 March 2013 (for PSF companies with a 31/12 closing date).

Circular 12/544: an immediate challenge that raises a number of questions

  • How can a risk management system be implemented swiftly and effectively?
  • How can a full understanding of the concepts and practices of a formalised risk management system be ensured?
  • How can reports be produced that meet the expectations of the regulator and allow for effective and dynamic monitoring of the risks identified, the relevant controls and the corrective action proposed?
  • Is it possible to enable this restrictive regulation to bring real added value to the evolution of the activities in question?
  • Who should be entrusted with this task?

Deloitte solutions

Our multidisciplinary approach and expertise both in the field of risk management and in the Support PSF sector allows us to help you cover every aspect of this new regulatory obligation.

Our personalised support allows you to:

  • Tackle the key points of the new regulation simply and pragmatically;
  • Identify and classify the risks as defined in the regulation, in a way that is adapted to your company’s individual situation;
  • Regularly review the impact and frequency of the various risks identified;
  • Prepare the different reports required by this CSSF circular.

An integrated or adjustable solution

Being fully aware of the issues facing Support PSFs, Deloitte has developed a simple, flexible, inexpensive and practical approach to help you deal with the challenges of Circular 12/544 as easily as possible. We will work closely with you to provide a full support service that will cover the organisational (training, internal processes), technical (tools, reports) and strategic (advice on risk hedging strategy) aspects of this Circular:

Financial Sector Risk Analysis Report (RAR) Direct and indirect risk management IT tool Descriptive Report (DR) Co-sourcing of risk management

1. Implementation and description of the system for managing financial sector risks (governance, methodology and tools used)

2. Self-assessment of direct or indirect risks and preparation for entering them in the IT tool provided

1. Individual detailed risk sheets: regular assessments

2. Register of direct and indirect financial sector risks

3. Monitoring of measures in place for reducing or transferring risks

1. Drafting of the report in accordance with the outline laid down in the Circular

2. Implementation and description of the system for managing financial sector risks (governance, methodology and tools used)

1. Reassessment of direct or indirect risks and updating in the IT tool provided

2. Financial sector Risk Analysis Report (RAR)

3. Updating of the Descriptive Report

4. Support Hot Line


1. Practical training in risk management 2. Practical training in the use of the IT tool 3. In-depth and refresher training

Our services

An integrated or 'à la carte' solution to provide you with the best possible support and enable you to control costs, including:

  • Training sessions on the basic concepts of risk management
  • Guidance in identifying your key risks
  • Setting up of the risk register; an efficient and automated solutions
  • Risk Analysis Report (RAR) preparation
  • Descriptive Report (DR) preparation
  • Long-term support in the form of co-sourcing of the risk management function

Deloitte - what makes us different

In choosing Deloitte, you will benefit from:

  • An affordable, quick, integrated or flexible formula
  • The support of professionals renowned for their extensive experience in risk management and expertise in your business sector
  • Tailored methodologies and technologies
  • Continuous support offering you both guidance and autonomy, according to your needs

Our team is committed to helping you improve the quality of your organisation and best overcome the challenges and take advantage of the opportunities presented by the CSSF regulation.


  • Stéphane Césari
    Partner - Audit - Financial Sector Professionals (PSF) Leader
  • Roland Bastin
    Partner - Information & Technology Risk
  • Raphaël Charlier
    Partner - Audit
  • Laurent Berliner
    Partner - EMEA Financial Services Industry Enterprise Risk Services Leader

Focus on

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Learn more

  • Pathfinder - Deloitte monthly regulatory update - February 2014
    AIFM. CRD IV / CRR. Central securities depositaries. Credit ratings. EMIR. EuSEF. SEPA. Solvency II. PSF - Authorisation. SRM and Single bank resolution fund.



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