Keltes

The RR and the RC under Article 11 of the AMLR

7 October 2026, Keltes

Article 11 of the AMLR names two compliance roles. Luxembourg texts already require two such roles of firms the CSSF supervises, and Belgian law, on our reading, which is not yet verified, does too. What matters is how the conditions compare, and part of that is still to be checked.

Two statements on this page rest on texts Keltes has not yet verified: what Belgian law requires under Article 9 of the Law of 18 September 2017, and the reference to a CSSF communication of November 2019 on the RR and the RC, which Keltes has not yet retrieved. Every other footnote quotes a text Keltes holds, and each quote is checked word for word against it.

What Article 11 requires

The Anti-Money Laundering Regulation (AMLR, Regulation (EU) 2024/1624) applies from 10 July 2027 for most obliged entities.1 Its Article 11 sets up two compliance roles. The first is the compliance manager: one member of the management body in its management function, responsible for ensuring compliance with the Regulation, with Regulation (EU) 2023/1113 and with any administrative act issued by any supervisor.2

The compliance manager must ensure that the entity's internal policies, procedures and controls are consistent with its risk exposure and are implemented, and that sufficient human and material resources are allocated to that end.3

The second role is the compliance officer, appointed by the management body in its management function and with sufficiently high hierarchical standing. The compliance officer is responsible for the policies, procedures and controls in the day to day operation of the entity's AML/CFT requirements, including the implementation of targeted financial sanctions, and is a contact point for competent authorities.4 The compliance officer is also responsible for reporting suspicious transactions to the Financial Intelligence Unit (FIU).5

The two roles meet in a report. The compliance manager must submit to the management body, once a year or more often where appropriate, a report on the implementation of the entity's internal policies, procedures and controls drawn up by the compliance officer, keep that body informed of the outcome of any reviews, and take the necessary actions to remedy any deficiencies in a timely manner.6

The two functions may be performed by the same natural person where the nature of the business, including its risks and complexity, and the size of the entity justify it, and they may be combined with other functions. Where the entity is a natural person, or a legal person whose activities are performed by one natural person only, that person performs the tasks under Article 11.7

Not new in Luxembourg

Neither role is new for a Luxembourg firm. The amended Law of 12 November 2004 requires a professional's policies, controls and procedures to include the appointment, at the appropriate hierarchical level, of a person responsible for the control of compliance with the obligations, known in practice as the RC.8 The same Article 4(1) requires professionals to designate, where applicable, from among the members of their management body or their effective management, the person responsible for compliance with the professional AML/CFT obligations, known as the RR.9

For professionals supervised, authorised or registered by the CSSF,1011 CSSF Regulation 12-02, as amended by CSSF Regulation 20-05 of 14 August 2020, is more specific. Professionals must designate an RR at the level of the authorised management or the board of directors,12 and must designate an RC.13 The same provision adds that investment fund managers and investment funds subject to the CSSF's AML/CFT supervision may appoint a third party.14

Luxembourg also already has an annual report. The RC prepares, at least once a year, a summary report on the RC's activities and functioning.15 The RR must submit that report to the CSSF every year, covering the past year, within five months of the end of the professional's financial year. This does not apply to Luxembourg investment funds that have appointed a Luxembourg management company which submits the report.16

Keltes' own materials refer to a CSSF communication of November 2019 on the RR and the RC. Keltes has not yet identified or retrieved that text, so this article says nothing about its content.17

Belgium, on our reading

In Belgium, our understanding is that Article 9, paragraphs 1 and 2, of the Law of 18 September 2017 require a senior manager responsible at the highest level for AML/CFT and an AML compliance officer, the AMLCO. Keltes holds the founder's copy of the text, not retrieved from the publisher by Keltes, and has not yet checked its wording, so this statement is our reading and is marked as unverified.18

What this means, and what is still to check

For a Luxembourg firm, and on our unverified reading for a Belgian one, the question is not whether to appoint two people. It is whether the people, mandates and reports it already has meet each condition of Article 11. Some conditions are worded differently in the texts quoted here. Article 11(1) speaks of a member of the management body in its management function.2 The Luxembourg law speaks of the management body or the effective management,9 and the CSSF Regulation of the authorised management or the board of directors.12 Whether those words point to the same person in a given entity is something to check for that entity, not to assume.

Before any of this becomes an answer for a particular firm, several things remain open: the Belgian text itself; the CSSF communication of November 2019; whether texts later than CSSF Regulation 20-05 changed the provisions quoted above; and how each entity is organised. Until our Luxembourg and Belgian national layers are verified and released by the founder, this article is our reading of the texts, not a verified comparison.

About this article

This article is general information about the texts it quotes, as they stood when it was written. It is not legal advice and does not replace advice on your own entity's situation. The Luxembourg texts are quoted in French, as published; the English descriptions of them are ours, not official translations.

Sources

  1. AMLR Art. 90, second paragraph It shall apply from 10 July 2027, except in relation to obliged entities referred to in Article 3, points (3)(n) and (o), to which it shall apply from 10 July 2029. ↑
  2. AMLR Art. 11(1), first subparagraph Obliged entities shall appoint one member of the management body in its management function who shall be responsible for ensuring compliance with this Regulation, Regulation (EU) 2023/1113 and any administrative act issued by any supervisor (‘compliance manager’). ↑
  3. AMLR Art. 11(1), second subparagraph The compliance manager shall ensure that the obliged entity’s internal policies, procedures and controls are consistent with the obliged entity’s risk exposure and that they are implemented. The compliance manager shall also ensure that sufficient human and material resources are allocated to that end. ↑
  4. AMLR Art. 11(2), first subparagraph Obliged entities shall have a compliance officer, to be appointed by the management body in its management function and with sufficiently high hierarchical standing, who shall be responsible for the policies, procedures and controls in the day-to-day operation of the obliged entity’s AML/CFT requirements, including in relation to the implementation of targeted financial sanctions, and shall be a contact point for competent authorities. ↑
  5. AMLR Art. 11(2), first subparagraph The compliance officer shall also be responsible for reporting suspicious transactions to the FIU in accordance with Article 69(6). ↑
  6. AMLR Art. 11(6) In particular, the compliance manager shall submit once a year, or, where appropriate, more frequently, to the management body a report on the implementation of the obliged entity’s internal policies, procedures and controls drawn up by the compliance officer, and shall keep that body informed of the outcome of any reviews. The compliance manager shall take the necessary actions to remedy in a timely manner any deficiencies identified. ↑
  7. AMLR Art. 11(7) Where the nature of the business of the obliged entity, including its risks and complexity, and its size justify it, the functions of the compliance manager and the compliance officer may be performed by the same natural person. Those functions may be cumulated with other functions. Where the obliged entity is a natural person or a legal person whose activities are performed by one natural person only, that person shall be responsible for performing the tasks under this Article. ↑
  8. Luxembourg, amended Law of 12 November 2004, Art. 4(1), second paragraph, point a) la gestion du respect des obligations, y compris la nomination, au niveau hiérarchique approprié, d'un responsable du contrôle du respect des obligations et la sélection du personnel Quoted from the Legilux consolidated text applicable from 8 August 2026, which is documentary only: only the texts published in the Journal officiel have legal force (product/sources/lu/README.md). ↑
  9. Luxembourg, amended Law of 12 November 2004, Art. 4(1), fourth paragraph Les professionnels désignent, le cas échéant, parmi les membres de leur organe de gestion ou de leur direction effective la personne responsable du respect des obligations professionnelles en matière de lutte contre le blanchiment et contre le financement du terrorisme. Quoted from the Legilux consolidated text applicable from 8 August 2026, which is documentary only (product/sources/lu/README.md). The words le cas échéant mean where applicable. ↑
  10. CSSF Regulation 12-02, Art. 2(1) Les dispositions du présent règlement sont applicables aux professionnels qui sont visés à l'article 2 de la Loi et qui sont soumis à la surveillance de la CSSF. Quoted from CSSF Regulation 12-02 of 14 December 2012 as published in the Journal officiel, in its original wording; Regulation 20-05 changed it (next footnote). ↑
  11. CSSF Regulation 20-05, Art. 3, point 1, amending Art. 2(1) of CSSF Regulation 12-02 Au paragraphe 1 les mots « soumis à la surveillance de la CSSF » sont remplacés par les mots « surveillés, agréés ou enregistrés par la CSSF, en ce compris les succursales au Luxembourg de professionnels étrangers notifiés à la CSSF ainsi que les professionnels de droit étranger notifiés à la CSSF qui fournissent des prestations de services au Luxembourg sans y établir de succursale. » Quoted from CSSF Regulation 20-05 of 14 August 2020 as published in the Journal officiel. The same article added a paragraph 3 that excludes audit firms and statutory auditors. Later amendments not verified. ↑
  12. CSSF Regulation 12-02, Art. 40(1), as replaced by CSSF Regulation 20-05, Art. 57 les professionnels doivent désigner un responsable du respect des obligations professionnelles en matière de LBC/FT au niveau de la direction autorisée ou du conseil d’administration selon les modalités précisées à l’article 1 du présent règlement. Quoted from CSSF Regulation 20-05 of 14 August 2020 as published in the Journal officiel. No consolidated text of Regulation 12-02 was found on Legilux on 6 October 2026, so whether later texts amended this provision has not been verified. ↑
  13. CSSF Regulation 12-02, Art. 40(1), as replaced by CSSF Regulation 20-05, Art. 57 En application de l’article 4 paragraphe 1, alinéa 2, point a) de la Loi, les professionnels doivent désigner un responsable du contrôle du respect des obligations professionnelles en matière de LBC/FT. Quoted from CSSF Regulation 20-05 of 14 August 2020 as published in the Journal officiel; later amendments not verified. ↑
  14. CSSF Regulation 12-02, Art. 40(1), as replaced by CSSF Regulation 20-05, Art. 57 Les GFIs et fonds d’investissement soumis à la surveillance LBC/FT de la CSSF peuvent nommer un tiers. GFI means gestionnaire de fonds d'investissement, investment fund manager (definition added by Regulation 20-05, Art. 2). Later amendments not verified. ↑
  15. CSSF Regulation 12-02, Art. 42(6), as replaced by CSSF Regulation 20-05, Art. 59 Le responsable du contrôle prépare au moins une fois par an un rapport de synthèse sur ses activités et son fonctionnement. Quoted from CSSF Regulation 20-05 of 14 August 2020; later amendments not verified. ↑
  16. CSSF Regulation 12-02, Art. 42(7), as replaced by CSSF Regulation 20-05, Art. 59 Le responsable du respect est tenu de soumettre annuellement à la CSSF le rapport de synthèse mentionné au paragraphe 6 ci-dessus portant sur l’année écoulée dans les cinq mois suivant la clôture de l’exercice social du professionnel. Cette exigence n’est pas applicable pour les fonds d’investissement luxembourgeois qui ont nommé une société de gestion luxembourgeoise qui soumet ce rapport annuel. Quoted from CSSF Regulation 20-05 of 14 August 2020; whether a later text changed this deadline has not been verified. ↑
  17. CSSF communication of November 2019 on the RR and the RCUNVERIFIED Not retrieved: the communication was not identified and the CSSF website gave no usable reply on 6 October 2026 (product/sources/lu/README.md). Nothing on this page rests on its content. ↑
  18. Belgium, Law of 18 September 2017, Article 9, paragraphs 1 and 2UNVERIFIED The Justel consolidation, from the founder's own copy, downloaded by him and uploaded on 8 October 2026 (UTC); not retrieved from the publisher by Keltes (product/sources/be/loi-2017-09-18-lbc/manifest.json). The public text on ejustice.just.fgov.be answered with a human verification page on 7 October 2026. Keltes has not yet checked the wording of Article 9. ↑
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