Luxembourg Commission de Surveillance du Secteur Financier updates AML CFT Market Entry Form triggers and removes certain IFM information fields

The Luxembourg Commission de Surveillance du Secteur Financier (CSSF) published updates to its AML/CFT Market Entry Form (MEF), which collects standardised key information on money laundering and terrorist financing risks for funds (including ELTIFs) and investment fund managers (IFMs) that are authorised or registered and supervised for AML/CFT purposes by the CSSF. The CSSF clarified that only specified requests, defined as “parent requests”, trigger the submission of an AML/CFT MEF, and the form must be submitted in parallel with such requests; entities are asked to submit the MEF only when a triggering event occurs. While completion of the form can be assigned within the eDesk portal to another employee or a third party, ultimate responsibility for adequate completion remains with the “RC” and “RR”. From 23 September 2025, the CSSF no longer requests information on Portfolio Manager(s) and Investment Advisor(s) in the AML/CFT MEF for authorised and registered IFMs, and these sections have been removed. The sections were automatically removed from MEFs in Draft or Reopened status (including MEFs submitted before that date), and remain only in MEFs that were already Closed before that date. The CSSF also reminded responsible persons to monitor MEFs that have been initiated but remain unsubmitted for more than one year, and expects these to be completed and submitted or deleted; supporting guidance is available via the eDesk user guide and FAQ.