RC Insight

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RC software for Luxembourg funds: the AML/CFT platform for the Responsable du Contrôle

RC software is a platform built for the Responsable du Contrôle (RC), the AML/CFT compliance officer that every Luxembourg investment fund and investment fund manager subject to AML/CFT supervision must appoint. It organises the RC's year, from the monitoring plan to the reports owed to the CSSF and the AED, and keeps the evidence in a single place.

RC Insight is RC software for Luxembourg funds.

What RC software does for a Luxembourg fund RC

RC software turns the RC's annual cycle into a plan, a record and a set of reports. The table maps each moment of the cycle to its deliverable and to its function in RC Insight.

Moment in the RC's year Deliverable RC Insight function
Start of the year Monitoring plan: controls, frequency and owner for each fund The monitoring plan; alerts and deadlines
Throughout the year AML/CFT policy, ML/TF/PF risk assessment and risk appetite statement (RAS), kept current Policy, risk assessment and RAS; risk appetite indicators
Throughout the year Due diligence on the transfer agent and other delegates Delegate due diligence
Throughout the year Testing of investor and asset data Investor KPIs; asset KPIs
Reporting season SRRC for the CSSF; AED questionnaire and RC report for RAIFs, and for other AIFs on AED invitation in 2026; summary report to the RR and the board CSSF and AED reporting
All year Evidence that the RC function worked, and awareness of new publications Audit trail; regulatory library

Why a Luxembourg fund RC needs a system

Every Luxembourg investment fund and every investment fund manager subject to AML/CFT supervision must appoint both an RR and an RC. The CSSF supervises Luxembourg IFMs and CSSF-regulated funds, while the AED supervises RAIFs and other AIFs not prudentially supervised by the CSSF. A RAIF is supervised by the AED even when its AIFM is CSSF-authorised. On the CSSF side, the SRRC (AML/CFT Summary Report RC) under Circular 24/854 is due within five months after the closing of the annual accounts, exclusively via eDesk. On the AED side, a RAIF's annual AML/CFT questionnaire and RC report are due by 31 May, a date the AED confirms each year. Our guide to annual AML/CFT reporting for Luxembourg funds sets out each deliverable by entity. In our view, these deadlines are easier to meet when the year's work and its evidence sit in the same system.

Ten functions, grouped by deliverable

All these functions are available in the platform today.

The monitoring plan

Plan the year's AML/CFT controls for each fund, record each test with its evidence, and follow findings to closure. Start from a control library and set the frequency and owner of each control. Findings and action points stay linked to the control that raised them, with their status and due date.

CSSF and AED reporting

Prepare the AED questionnaire and RC report and the CSSF report section by section in the platform, and track progress to submission: you see what is complete, what is missing and what remains to be reviewed. The rules behind each report are in our guides to the SRRC under CSSF Circular 24/854 and the AED RC report and questionnaire for RAIFs.

AML/CFT policy, risk assessment and RAS

Generate the fund's AML/CFT policy, ML/TF/PF risk assessment and risk appetite statement from its recorded data, then review, approve and export them. The annual ML/TF risk assessment no longer has to be filed with the SRRC, but it must still be performed and documented. Risk appetite indicators, such as the share of PEPs or of investors from high-risk jurisdictions, are tracked against the limits the board has set.

Delegates

Send due diligence questionnaires to the transfer agent and other delegates through a secure link, and track answers, reminders and follow-up questions. When a CSSF-supervised professional outsources customer due diligence, responsibility stays with the professional, which must carry out a regular control of the delegate's compliance with the contract, on a risk basis.

Investors and assets

Collect the transfer agent's investor data through a secure upload and see the fund's investor base by country, risk level, PEP status and sanctions screening. Record each portfolio asset with its type, valuation, country and risk level, and see where the fund's asset-side ML/TF risk sits. The AED RC report covers due diligence on the fund's assets among its topics.

Alerts and deadlines

Get notified when a due diligence review falls due, a reporting deadline approaches or an indicator crosses its limit.

Regulatory library

Follow CSSF publications and regulatory updates in a searchable library, filtered by category and date.

Audit trail

Every action is logged with its author and date, so you can show the board, the auditor or the supervisor who did what, and when.

Who RC software is for

  • Independent RCs with several fund mandates: controls planned for each fund, and every deadline and open point of each fund in a single view. See RC Insight for independent RCs.
  • AIFM and ManCo compliance teams: the manager's SRRC and the funds it manages, including RAIFs supervised by the AED. See RC Insight for AIFMs and ManCos.
  • Providers of RC services: the same method and the same standard of evidence across the funds they follow. See RC Insight for service providers.

Launching a fund and need an RC? Talk to us about an RC for your fund.

See RC Insight in a demo

In a demo, the RC Insight team walks you through the RC's year in the platform: monitoring plan, delegate questionnaires, investor and asset data, reports for the CSSF and the AED.

Request a demo

FAQ

Who files the reports with the CSSF and the AED?

In RC Insight, you prepare each report; the RR or the RC files it with the supervisor. The RC prepares the SRRC; the RR submits it and remains accountable. For a RAIF, the RR transmits the AED questionnaire and may mandate the RC. In our practice, every communication with the supervisors stays under the RR's responsibility.

Does RC Insight cover funds supervised by the CSSF and by the AED?

Yes. The CSSF supervises Luxembourg IFMs and CSSF-regulated funds; the AED supervises RAIFs (even when their AIFM is CSSF-authorised) and other AIFs not prudentially supervised by the CSSF. In RC Insight, you prepare the CSSF report as well as the AED questionnaire and RC report.

Is RC Insight a KYC or screening tool?

No. RC Insight does not replace the transfer agent's onboarding and screening. It is RC software: the transfer agent uploads its investor data through a secure link, and the RC sees the investor base by country, risk level, PEP status and sanctions screening, so the data can be tested and questioned.

Can an RC follow several funds in RC Insight?

Yes. Controls are planned for each fund, with their frequency, owner and evidence. Notifications and the RC calendar bring every deadline and every open point of each fund into a single view, so nothing depends on a spreadsheet or a reminder in someone's inbox.

Does RC Insight draft the AML/CFT policy and the risk assessment?

RC Insight generates the fund's AML/CFT policy, ML/TF/PF risk assessment and risk appetite statement from its recorded data. The RC reviews and edits the draft, then the RR and the board approve it; the final document is exported to Word. Article 38(4) of CSSF Regulation 12-02 requires board validation of the AML/CFT policy.

What can I show the board, the auditor or the supervisor?

The audit trail. Every action is logged with its author and date, including changes to funds, controls, findings, documents and reports. It shows who did what, and when: the evidence that the RC function worked during the year, not only at reporting time.

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