Roles and responsibilities of the RR and RC
ALCO (The Association of Luxembourg Compliance Officers) organised an online Round Table on the “Roles and Responsibilities of the RC & RR". ALCO presented the results of a survey among its members while the CSSF (Commission de Surveillance du Secteur Financier) summed up the discussion with their views on the matter.
Partner Sophie Dupin participated as an expert on the legal responsibilities and regulatory framework of the RR (responsable du respect des obligations) and the RC (responsable du contrôle du respect des obligations).
Every Luxembourg Investment Fund subject to AML/CFT supervision is legally required to appoint one person for each of these two roles. The RR can be the board of directors (or other governing body) acting as a collegial body or, alternatively, the board may also appoint one of its members. The RC is selected by the board of directors (or other governing body) of the Fund. The RC may also be a board member with appropriate experience or a third party.