SLP - Is the Responsable de Control and Registration with CSSF is included in our pricing?
Milo / 28.06.2021
"for a regulated Luxembourg fund the responsable du contrôle du respect des obligations (RC) is a person employed by the AIFM, normally its MLRO. However, twhen the AIFM is not based in Luxembourg, as it is the case for Abalone Asset Management, this requirement by the CSSF is not applicable as not enforceable by the CSSF itself. Having said that, our AIFM does have an MLRO which fulfills AML responsibilities similar to what an RC does.
What the Luxembourg fund instead must have is the responsable du respect des obligations (RR), which typically is a Luxembourg-based director of the fund. Since our offer limits itself to AIFM service, such service and related quote is not included in our offer and will be quoted when reaching out to other service providers once we obtain the structuring mandate.
Please see attached for a better understanding."