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)
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 officer designations.
Suggested Considerations
- Download and use the XLSX table: Incorporate the exact list of activities/mandates into internal templates for reporting management body and conducting officer roles[Source URL].
- Update authorization and notification files: Include detailed CVs, criminal record extracts, wealth declarations, and organization charts for relevant personnel/shareholders; notify CSSF of changes (e.g., qualifying holdings, guarantees).
- Conduct fit-and-proper assessments: Ensure declarations cover all listed mandates, demonstrating no conflicts and adequate resources; perform initial/ongoing due diligence on delegates.
- Annual compliance review: Document roles in compliance monitoring plans, training, and reporting to senior management/CSSF; align with delegate oversight (e.g., risk-based monitoring of compliance, audit functions).
- Policy updates: Revise governance policies to reflect the updated list, including AML/CFT officer designations and own funds proofs.
Key Dates
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
References
AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.
Summary
Table listing the professional activities and the mandates performed