Communication
On 30 September 2025, the CSSF published a communication on the AML/CFT Market Entry Form (“MEF”). The MEF aims at collecting standardised key information in relation to money laundering and terrorist financing risks which must be submitted by funds (to be) authorised (including ELTIFs irrespective of AIF type) and investment fund managers (“IFMs”) (to be) authorised or registered that are supervised for AML/CFT purposes by the CSSF.
Requests triggering the submission of the MEF:
- Fund: upon authorisation (including authorisation/registration under a European label, i.e. ELTIF, EuSEF or EuVECA)
- Fund: adding (a) sub-fund(s) only if at least one of the following events are triggered by the new sub-fund(s):
- new initiator(s);
- new founder(s);
- sub-fund(s) designed for a limited number of investors;
- additional/new type of investments
- ELTIF (other than Part II UCI, SIF, SICAR): upon notification of (a) new (change of) manager(s)/director(s), “RR” or “RC”
- IFM: upon authorisation
- IFM: modification of qualified shareholding
- IFM: upon registration as an AIFM pursuant to Article 3 of the AIFM Law.
These requests are also defined as “parent requests” which trigger the parallel submission of the MEF.
Initiation and submission
The CSSF reminds that the MEF must be initiated and submitted by the compliance officer in charge of the control of compliance with the professional (“RC”) or the person responsible for compliance with the professional obligations (“RR”).
Nevertheless, the completion of the MEF may also be assigned via eDesk to another employee of the respective entity or even third party, but the final responsibility for the correct completion remains with the RC and RR.
Removed sections
Since 23 September 2025, the sections ‘Portfolio Manager(s)’ and ‘Investment Advisor(s)’ for authorised and registered IFMs have been removed by the CSSF in the MEF. These sections have been removed by the CSSF in any already existing MEF with status ‘Draft’ or ‘Reopened’ (incl. MEF submitted before this date) even if they were completed beforehand. However, MEFs initiated before 23 September 2025 with the status ‘Closed’ will retain these sections.
CSSF reminder
The CSSF also takes the opportunity to remind the persons responsible for the completion of the MEF that regular monitoring must be carried out on a MEF that has already been initiated (i.e. a draft MEF) but has not been submitted to the CSSF after one year. In that case such MEFs are expected to either be completed and submitted, or deleted.
FAQ update
On the same date, the CSSF updated the related FAQ for the MEF (“FAQ”). As stipulated in our last article on the FAQ, it provides clarifications on the circumstances in which the MEF must be submitted or updated, and on the information and documents required by the CSSF.
Overview of changes
The FAQ update includes revisions to the questions 1, 5 and 6.
Question 1 has removed the requirement for authorised investment fund managers (“IFMs”) to complete and submit the MEF, in the case of:
- approval of an additional licence or a licence extension; and
- mergers.
Question 5 clarifies that managers/directors already approved within the same specific fund or IFM do not have to provide new documentation (CV, declaration of honour etc) when a new MEF is submitted.
Lastly, question 6 clarifies that documentation for a new RC can only be submitted via the E-Desk if the RC changes at the same time as a trigger event for the submission of a MEF occurs.
The updated FAQ may be found here.
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