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Financial Record Keeping Requirements in Luxembourg Clarified by CSSF and ESMA Guidelines

The Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg has issued a circular to provide clarity on financial record keeping requirements for investment firms operating in the country. This follows closely with European Union regulations, specifically those related to the Markets in Financial Instruments Regulation (MiFIR) and the Markets in Financial Instruments Directive (MiFID II).

Key Areas of Focus

  • Transaction Reporting: Firms must maintain accurate records of transactions conducted on trading venues, as well as details on orders that are executed or rejected.
  • Clock Synchronisation: Electronic systems must be in sync with Coordinated Universal Time (UTC) to prevent discrepancies in trade reporting times.

ESMA Guidelines for Transaction Reporting

The European Securities and Markets Authority (ESMA) guidelines provide further clarity on transaction reporting requirements under MiFIR. The guidelines detail the specific information that must be included when reporting transactions, such as:

  • Unique Client Reference Number (UCRN): Each client’s unique reference number must be included to accurately attribute transactions.
  • Transaction Details: Firms must report details about each transaction, including the date and time of execution.

Supporting Materials

The CSSF circular is accompanied by a detailed guide from ESMA on transaction reporting under MiFIR. The guide provides a comprehensive overview of the requirements, including examples and explanations to help firms understand the complexities of the regulations.

Recommendations for Investment Firms

Investment firms operating in Luxembourg are advised to review their internal procedures and ensure they are meeting the necessary record keeping requirements. This will not only help them maintain regulatory compliance but also support market integrity by ensuring accurate transaction data is available for analysis and oversight.