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 Xavier Balthazar, Birgit Goldak and Benjamin Gauthier, Partners at PwC Luxembourg

• Xavier Balthazar is a partner in the regulatory practice at PwC Luxembourg, specialising in financial sector and funds regulations. He has extensive experience in setting up and restructuring investment funds, management companies, and financial sector professionals both in Luxembourg and internationally, focusing on their organisation, processes, and procedures. Xavier serves as a regulatory compliance expert for depositary banks and fund administrations and leads a regulatory watch service for banks and asset managers. His expertise includes legal and regulatory aspects of investment funds, licensing of financial professionals, and UCITS and alternative investment funds. He has contributed to client projects involving licensing, compliance adaptation, fund administration, and regulatory training, and is a recognised speaker at industry conferences.
• 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.