Focus on CSSF circular 18/698

• Chapter 15 ManCos
• Management companies incorporated under Luxembourg law subject to article 125-1 or article 125-2 of chapter 16 of the 2010 law ('chapter 16 ManCos')
• Luxembourg branches of IFMs subject to chapter 17 of the 2010 law ('chapter 17 ManCos')
• Self-managed management companies (SIAG)
• Authorised AIFMs under chapter 2 of the 2013 law
• Internally managed AIFs within the meaning of article 4(1)(b) of the 2013 law ('fonds d'investissement alternatifs gérés de manière interne' or 'FIAAG

The CSSF circular 18/698 mirrors a lot of best practices already existing in the market but also introduces new requirements on the 'authorisation and organisation of Luxembourgish investment management companies; specific provisions on the fight against money laundering and terrorism financing applicable to investment fund managers and entities carrying out the function of registrar agent.'

Our training covers each chapter of the circular in order to capture the main impacts of the requirements and support our participants in identifying the impacts of this circular on their organisation.

By the end of this training, the participants will be able to:

• determine the regulatory requirements introduced by the CSSF circular 18/698
• understand in detail the impacts of the circular on the control of delegation, AML/KYC, risk management and valuation requirements

• An overview of the new circular
• Impacts on control of delegation
• Impacts on risk management and valuation
• New requirements on control of the distribution network and AML/KYC

This training is coordinated by Anthony Bianco, Birgit Goldak and Benjamin Gauthier, Partners and Claudia Tripodo, Director at PwC Luxembourg.

• Anthony Bianco is a partner at PwC Luxembourg, co-leading Internal Audit and Regulatory Advisory services for Financial Sector clients, including Asset Management and Banks. With over 18 years of experience in internal and external audit, he holds a Certified Internal Auditor (CIA) qualification. Anthony oversees numerous compliance and regulatory advisory projects within the Asset Management and Alternatives industries, focusing on CSSF inspection preparation, licensing processes, compliance methodologies, and policy development. His expertise spans Internal Audit, Asset Management, Regulatory Compliance, and AML/CFT/KYC, with notable client projects involving management companies, alternative investment fund managers, specialised PFS, fund administrators, registrar agents, and depositary banks.
• Birgit Goldak is a partner and Risk Assurance expert at PwC Luxembourg, specializing in Asset Management and the alternative investment funds industry with over 20 years of international experience. She leads PwC’s AML Services, focusing on Alternatives, Asset Management, Distribution, and Counter Party Due Diligence, while also providing Trust and Transparency Solutions and Internal Audit Services. Birgit is a recognised subject matter expert involved in the AML core working group of the Luxembourg Fund Association for Investment Funds and contributes to AML AFLI Guidelines. She actively participates in the EFAMA AML group, advising on EU AML legislation and engaging with Luxembourg regulators. Her client projects include AML governance, risk assessments, audits, forensic investigations, regulatory advice, and ISAE reporting.
• Benjamin Gauthier is a partner in PwC Luxembourg’s Regulatory and Compliance consulting team, specialising in Risk Management and governance for the Asset Management industry, with advisory services for private equity. He leads the Risk Management for Asset Management team and the “Managed Services” outsourcing initiative. With 20 years of experience as a Risk Manager and consultant in investment funds and asset management, Benjamin has developed strong expertise in these sectors. He is an active member of ALFI/AIFMD and serves on the board of ALRiM, the Luxembourg association of risk managers. His work includes regulatory reporting, governance, ESG, and risk monitoring solutions for global clients.
• Claudia Tripodo is a director in the Regulatory Compliance Advisory Department at PwC Luxembourg, with over 6 years of experience in the asset and wealth management industry. She specialises in fund set-up, regulatory maintenance, restructuring projects, licensing of financial sector professionals and management companies, and reviewing management company activities to ensure compliance with regulatory requirements. Her responsibilities include drafting and reviewing fund documentation, management policies, and CSSF intermediation, as well as conducting gap analyses and remediation plans for new laws and regulations. Claudia has led key projects involving UCITS and alternative investment funds, sustainable finance, regulatory updates, and has delivered internal and external training sessions.