How to register a Luxembourg VASP?

Generally, the VASP registration procedure starts with a meeting at the CSSF premises. This meeting aims at presenting, both, the applicant and its project. The CSSF will then determine, based on the projected activities, whether a VASP registration may be necessary. In case the applicant submits a formal registration file to the CSSF, it must include all the required documents and information (CSSF, VASP Registration procedure, p. 2).

 

The CSSF may also expect from each AIF initiator intending to invest in Virtual Assets to present its project beforehand to the CSSF (CSSF, FAQ Virtual Assets – Undertakings for collective investment, Q.3, p. 4).

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Documents and information must be submitted to the CSSF beforehand, exclusively in an electronic form through a specific system. Naturally, the submission does not imply an automatic registration. The registration will only be effective once the CSSF added the VASP to its register (CSSF, VASP Registration procedure, p. 2).

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After submission, the CSSF will then examine the registration file. It may exchange with the applicant and organise meeting(s) with it. Among the elements verified by the CSSF is the legal requirement for the applicant professional standing (“fit & proper”) of the persons performing a management function within the VASP as well as the VASP beneficial owners. The CSSF may request additional information/documents during the registration process (CSSF, VASP Registration procedure, p. 2).

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The registration will take place once the CSSF finished its analysis, and a formal registration decision has been taken by it. The entity details are then published in a public register established, kept and maintained by the CSSF. If significant changes would occur to the VASP activities after its registration, the registered VASP must immediately inform the CSSF in writing (CSSF, VASP Registration procedure, p. 3).