On 22 December 2021, the Commission de Surveillance du Secteur Financier (CSSF) published three new Circulars (CSSF 21/788, 21/789 and CSSF 21/790) that require self-assessment questionnaires (SAQs) to improve the monitoring of investment fund managers (IFMs) and investment funds, as well as anti-money laundering and counter-terrorist financing (AML/CTF):
What does this mean for you? As an IFM you need to:
The Board of Directors of the fund are ultimately responsible for accurate self-assessment questionnaires (SAQs). UCITS funds have to be submitted via eDesk three months after fiscal year-end—at latest—while UCI part II, SIFs and SICAR must be completed in four.
Practically speaking, accurately completing a fund’s SAQ has proven to be quite difficult; it can generate a workload that requires highly technical skills, which can quickly become time consuming and drain resources.