CSSF Circular 18/698

September 7, 2018

On 23 August 2018, the Commission de Supervision du Secteur Financier ( the “CSSF”) issued a new circular 18/698 ( the “Circular”) related to the authorization and organization of Luxembourg investment fund managers and the fight against money laundering and terrorist financing (“ML/FT”) applicable to them and to entities carrying out the function of registrar agent.


The Circular replaces CSSF Circular 12/546 whose scope has been extended as it applies now to both UCITS management companies and alternative fund managers, as well as to managements companies subject to chapters 16 and 17 of the law of 17 December 2010 related to undertakings for collective investment.


The Circular takes into account the most recent regulatory practices that were applied by the CSSF and the evolution of European and local legal instruments on alternative investment funds and on the fight against ML/FT.

It also brought some specific new requirements related to the governance and organizational structure of the investment fund managers. The Circular emphasizes the need for investment fund managers to have the appropriate volume of human resources in place. By instance, the Circular specifies the required number of conducting officers and defines threshold on the time spent and number of mandates that conducting officers and directors are authorized to hold.

The Circular formalizes the rules to be followed by the investment fund managers for a proper governance, e.g. management committees meetings, board of directors meetings.

The Circular introduces new information to be provided by the investment fund managers to the CSSF, e.g. annual reporting in terms of ML/FT, transmission of risk management policy template regarding AIFs.

The Circular sets out details on the ML/FT framework in relation to the investment funds, the investors, the intermediaries involved in the marketing and also the investments made on behalf of the investment funds. It also provides additional requirements details on the due diligence measures and on-going monitoring of the investment fund managers’ delegates.

The Circular also provides for specific provisions for the portfolios management activity.


CSSF Circular 18/698


Our expanding business already obliged us to conduct deep review of our internal governance design and was for us the opportunity to improve our governance operating model and our reporting structure.

Our growth and our significant size is definitively an advantage in the maintenance of a proper and effective governance implementation. Our team of specialists continue exploring whether changes to our existing processes and procedures may be necessary to support the complete integration of the Circular.



June 18th, 2018


Lemanik Asset Management S.A, the Luxembourg based Management Company and AIFM with presence in Dublin and Milan , has announced the appointment of Mr Alessandro Silvestro as Managing Director Asia Pacific. Based in the newly created office in Hong Kong, Alessandro will join the management committee and report directly to Mr Philippe Meloni, Lemanik Group CEO.
Alessandro, 43, graduated with a master degree in law (LLM), brings 18 years of experience in the investment fund business. Over the course of his career, he has developed operational, sales & relationship management expertise in both Europe and Asia. He held various senior positions with RBC Investor Services in Luxembourg, Milan and Hong Kong. Most recently, he was Head of Sales at Standard Chartered Hong Kong focusing on the fast growing insurance segment in Asia.
The appointment comes amid a rising interest among Asia Pacific traditional and alternative asset managers to set up UCITs, AIFs, RAIFs or ICAVs. 


Alessandro said:

“Lemanik has always been committed and successful to Asia Pacific as 20% of our clients already come from the region. 
Asian clients are probably the most demanding and sophisticated in the world. Our onshore presence will elevate and differentiate our offering, immediately addressing our clients’ needs. As Asia Pacific is now represented at the management committee, Lemanik has raised the bar to a whole new level for the Management Company business. 
Already a leading Management Company, Lemanik is the #SuperManco of reference to support Asia Pacific investors’ internationalization.
I do look forward to meeting our clients and partners to share our unique solutions for their UCITS, and AIF projects.”



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