Deterministic core
Limits, risk figures, NAV checks and deadlines are versioned, tested and reproducible code. The same input gives the same result.
A project for Luxembourg
An investment fund manager where the platform does the work and people make the decisions.
ifm.lu is building the operating model and the software for a Luxembourg Super-ManCo: an investment fund manager (IFM) that is both a UCITS management company and an AIFM, and launches and manages UCITS and alternative investment funds (AIFs). It runs with the smallest team the law allows. Execution, monitoring and evidence are automated. Every decision stays with a named person.
Status: this is a project in preparation. ifm.lu is not authorised by the CSSF, manages no funds and offers no services. Nothing on this site is an offer, a solicitation or investment advice.
Approach
A Luxembourg IFM delegates much of its work: portfolio management, fund accounting, transfer agency. The one thing it cannot delegate is the oversight of those delegates. That is where most of the manual effort goes today, in spreadsheets, sample checks and email.
We start there. The platform checks every delegate, every limit and every deadline, every day, and records each check as evidence. The conducting officers and the board decide on what it finds.
Three people with a platform that checks everything can oversee more, and more reliably, than twenty people working from spreadsheets and samples.
Terms
- IFM
- Investment fund manager: the umbrella term for UCITS management companies and AIFMs.
- ManCo
- UCITS management company under Chapter 15 of the Law of 17 December 2010.
- AIFM
- Alternative investment fund manager under the Law of 12 July 2013, managing AIFs.
- Super-ManCo
- A ManCo that is also authorised as an AIFM. ifm.lu is planned as one, to manage UCITS and AIFs from one entity.
Principles
AI assists, never approves
AI agents read documents, draft reports and sort alerts. Each works under a written mandate with a responsible person. None of them decides or sends anything out on its own.
Named approvals
Every decision with regulatory or external effect needs the approval of a named person, and two where the four-eyes principle applies.
Evidence by default
Each step stores its input, rule version, result, approval and timestamp in an immutable archive that auditors can read directly.
Full checks, not samples
Where a manual process would test a sample, the platform tests the whole population, and it does so daily.
Vendor-neutral and portable
A canonical data model with one adapter per administrator, transfer agent or depositary. Infrastructure as code keeps an exit to another provider possible.
From rule to evidence
Every requirement is traceable, from the legal text to the proof that the control ran.
- NormLaw, regulation, CSSF circular or guideline
- RequirementEach obligation as its own catalogue entry
- Policy & procedureWhat we commit to do, in plain Markdown
- ControlHow the platform checks it
- TestProof that the control works
- EvidenceProof that it ran, stored immutably
What the platform covers
Roadmap
We apply for authorisation only once everything is ready. The phases follow maturity, not dates.
Foundation
Norm register and requirement catalogues, document templates, repository structure.
Documentation
Policies and procedures, programme of activity, risk management process, AML risk assessment.
Platform core
Governance, master data, data hub, evidence archive, regulatory calendar, delegate oversight.
Control engines
Investment compliance, risk, NAV and TA oversight, AML, reporting, AI agents.
Dress rehearsal
Shadow operation with simulated funds, mock audit, penetration and resilience tests.
Authorisation
Application to the CSSF for authorisation as a ManCo and as an AIFM, including a demonstration of the platform.
Contact
ifm.lu is a project of concilio et labore GmbH. If you work on fund governance, supervision or fund operations and would like to exchange views, write to us.