On 21 June 2021, the CSSF published the FAQ Market Entry Form ("FAQ") regarding the completion of the AML/CFT market entry form ("MEF") via eDesk for UCIs and IFMs. The CSSF clarifies the events that shall trigger the submission of a MEF as well as the type of MEF which shall be submitted.
For the sake of clarity, the MEF is submitted at the umbrella level including up-to-date information on all sub-funds (and not one MEF per sub-fund).
Only the person responsible for the respect of compliance ("RR") and the person responsible for compliance of the UCI ("RC") have the rights to initiate and submit the MEF. Others (delegates) may contribute to the completion of the MEF before its final submission to the CSSF via eDesk by the RR or the RC.
The FAQ also clarifies that certain documents normally attached to the MEF do not need to be re-included if they have been filed previously and they have not changed.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
