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Is the role of the Responsable du respect des obligations (RR) truly effective in its day-to-day execution within the existing framework? Should the RR function be assigned to a sole individual or collectively to the Board members? This article analyzes the current structure of the Board on Investment Funds in Luxembourg, understanding how the RR function is currently managed, where the board individually or collectively holds the function of RR, identifies its inherent weaknesses, and explores potential future developments.
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I am Diego Ofano, a Compliance and Anti-Money Laundering professional based in Luxembourg. I serve as Conducting Officer and RC/MLRO for a financial institution, overseeing regulatory compliance for EU-domiciled funds. My responsibilities include AML/CFT frameworks, due diligence, regulatory advisory, and training. I regularly deal with complex regulatory and operational matters, with a focus on pragmatic and risk-based solutions in the investment funds industry.
I hold a Law Degree from the University of Bologna, a Master in European Business from ESCP, and certifications like CAMS, keeping me current in compliance and technology.