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List of professional activities and mandates performed by members of the management body/governing body and by conducting officers (points 105 and 107 of Circular CSSF 18/698) (Updated)

AI Analysis

Executive Summary

This CSSF publication is an updated table (in XLSX format) listing standardized professional activities and mandates for members of the management body/governing body and conducting officers, as required under points 105 and 107 of Circular CSSF 18/698. It matters because it ensures consistent, transparent reporting of senior personnel roles in Luxembourg investment fund managers (IFMs), supporting governance, conflict-of-interest management, and CSSF supervisory oversight. Compliance professionals must use this list to standardize disclosures in authorization files and ongoing reporting. #

What Changed

The document was originally published on 14 January 2019 and updated on 12 March 2026, reflecting revisions to the predefined list of professional activities and mandates[Source URL]. Key aspects include: - Alignment with Circular CSSF 18/698 requirements for IFMs (management companies for UCIs and AIFs), specifying reportable roles like those in collective portfolio management, risk management, valuation, compliance, internal audit, and IT operations. - Emphasis on detailed documentation of mandates to demonstrate fitness, properness, and avoidance of conflicts, including for shareholders with qualifying holdings. - No entirely new requirements introduced, but the update likely incorporates evolving governance expectations, such as enhanced delegate oversight and AML/CFT compliance office

What You Need To Do

  • Download and use the XLSX table
  • Update authorization and notification files
  • Conduct fit-and-proper assessments
  • Annual compliance review
  • Policy updates

Key Dates

14 January 2019 - Original publication of the list.
23 August 2018 - Publication of underlying Circular CSSF 18/698, setting baseline requirements.
End of May (post-financial year) - Compliance deadline for Circular 18/698 obligations, including governance reporting (e.g., 5 months after year-end). DEADLINE
12 March 2026 - Latest update to the list, requiring immediate review and integration into reporting processes[Source URL].

Compliance Impact

Urgency: High – The March 12, 2026 update coincides with today's date, demanding immediate review to avoid supervisory findings during CSSF inspections or authorization processes. Non-compliance risks authorization delays, fines, or reputational damage, as Circular 18/698 emphasizes robust governance in a heightened scrutiny environment for IFMs (e.g., delegate oversight, AML).

Who is Affected

Primarybased IFMs (Management Companies or ManCos) authorized under the 2010 Law (UCIs) and/or 2013 Law (AIFs), including those managing UCITS, AIFs, SIFs, SICARs, or providing discretionary management.SecondaryOthersdelegates (e.g., for IT, accounting, compliance functions), and groups submitting authorization files.

Summary

Table listing the professional activities and the mandates performed

Relevant Firm Types

Asset ManagerBankAll Firms
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