Clearstream Fund Desk

Regulatory compliance – «AML/KYD documentation»

Now available for download on the Fund Provider Portal

According to the SFAMA (Swiss Funds & Asset Management Association) guidelines for the distribution of collective investments dated 22 May 2014 and with the extended due diligence obligations introduced by EU Directive 2015/849 of the European Parliament, you are obliged to exercise increased monitoring obligations towards your distributors.

To provide Fund Providers with the best possible support in this respect, the Fund Desk has collected AML Wolfsberg questionnaires, created its own standardised "Know Your Distributor" (KYD) questionnaire based on those recently received (since MiFID II) from all the Fund Providers together with the usual annual SFAMA declarations and attachments. The Fund Desk has further developed the Fund Provider Portal in order to make available the relevant AML and KYD documents for download including the SFAMA questionnaires and declarations of sanction compliance of each of the distribution partners. A further value added is the implemented archiving function, which allows Fund Providers to download documents of previous business years. By sharing these documents with Fund Providers, we are convinced this provides enhanced transparency and information about the distribution activities of each distribution partner.

The Fund Desk has collected the following documents from distribution partners:

  • SFAMA Distributor Questionnaire

    Declaration for the supervision of distributors of collective investment schemes (incl. appointment of Sub-Distributors and other information) Note: this was previously circulated by email and hard copy.

    Newly available documents

  • AML Wolfsberg Questionnaire

  • Fund Desk "Know Your Distributor" Questionnaire

    The KYD questionnaire created by the Fund Desk supports Fund Providers in fulfilling the new and expanded due diligence obligations introduced by the above-mentioned EU directives.

  • Power of Attorney (PoA)

    Each Distribution Partner provides authority to the Fund Desk to sign Distribution Agreements on its behalf

  • Declaration of Sanctions Compliance

    Each Distribution Partner confirms that it has carried out appropriate screening of its clients or customers in accordance with the selected sanctions lists

For security and confidentiality as well as efficiency reasons, the Fund Desk will no longer send out the SFAMA documents via email. As a consequence, Fund Providers will need to register to the Fund Provider Portal

Registration

To access the Fund Provider Portal you are asked to complete the registration process by following the instructions on the link: https://clearstream.funddesk.com/FPP/register

Legal and KYD documents section (newly available)

Once you are registered and logged in to the Fund Provider Portal, KYD documents are available for download in the section "Legal Documents" in the tab "KYD Documents".

If you have any questions or if you require assistance with the registration process please do not hesitate to contact your usual relationship managers in Zug.

Contact Client Services Team

Global Head of Network, Investment Fund Services
Ralph Hug
ralph.hug@clearstream.com
+41 43 430 71 51

Network Manager, Asset Manager Network – Investment Funds Services
Franco Iseppi
franco.iseppi@clearstream.com
+41 43 430 71 52