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
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.
Key dates
- 23 August 2018
- - Publication of underlying Circular CSSF 18/698, setting baseline requirements
- 14 January 2019
- - Original publication of the list
- 12 March 2026
- - Latest update to the list, requiring immediate review and integration into reporting processes[Source URL]
- End of May (post Deadline
- financial year); - Compliance deadline for Circular 18/698 obligations, including governance reporting (e.g., 5 months after year-end)
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.
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.
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
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.
What the CSSF said
Table listing the professional activities and the mandates performed
Published by CSSF . Read the full notice at the source for the authoritative text.