Secondment Services

Approved. Experienced. Operational from Day One.

Strategy Supervised Function Secondment — CSSF-Approved Key Function Holders, Operational Secondment — Experienced Professionals Across Functions

Secondment Services

For Luxembourg-regulated entities, the sudden departure of a key function holder or the emergence of an unexpected capacity gap — whether in a regulated compliance role, a finance or valuation function, a risk management position, or an ICT or ESG officer role — is not merely an HR challenge. It is an operational and, in many cases, a regulatory risk that requires an immediate, structured response. Regulated roles cannot remain vacant without creating exposure to the CSSF, the board, and the entity’s operational continuity.

HACA Partners’ Secondment Services address this challenge directly. We provide experienced professionals who are ready to step into regulated roles immediately — individuals who already hold CSSF approval for equivalent functions, who understand the Luxembourg regulatory environment from day one, and who bring with them the market practice, professional judgment, and governance standards that regulated entities require. Our model is built around a single priority: continuity without compromise.

Unlike traditional recruitment, a HACA Partners secondment requires no extended onboarding, no regulatory re-approval process for equivalent roles, and no learning curve on Luxembourg regulatory expectations. Our professionals arrive plug-and-play — ready to fulfil the obligations of the role, engage with the CSSF, report to the board, and maintain the governance standards the entity requires, from the first day of their assignment.

Services

1. Supervised Function Secondment — CSSF-Approved Key Function Holders

Certain roles within Luxembourg-regulated entities — AIFMs, management companies, investment firms, and PSFs — are subject to formal CSSF approval or notification requirements. When these roles become vacant, even temporarily, the entity faces both a regulatory obligation and an operational gap that cannot wait for a standard recruitment process. HACA Partners can provide CSSF-approved professionals to fill these positions immediately, ensuring uninterrupted regulatory compliance and governance continuity.

The supervised and key functions we cover include, among others:

Conducting Officer (Dirigeant Agréé): approved senior managers who can assume immediate responsibility for the day-to-day direction of an AIFM or management company, maintaining regulatory accountability, board-level engagement, and CSSF-facing obligations without interruption.

Conducting Officer for Valuation: approved specialists who can step into the oversight of the independent valuation function, ensuring continuity of AIFMD valuation compliance and CSSF expectations throughout the assignment.

Compliance Officer (Responsable de la Conformité): experienced compliance professionals ready to assume the compliance function across MiFID II, AIFMD, AML/CFT, and GDPR — maintaining the compliance programme, board reporting, and regulatory interactions without disruption.

Risk Manager: qualified risk professionals who can take over the risk management function — covering market, credit, liquidity, and operational risk frameworks — ensuring continuity of risk oversight and reporting to senior management and the board.

AML/CFT Responsable du Contrôle (RC): in close coordination with our AMLRO service offering, our RC-approved professionals can assume the full AML oversight function immediately, including board reporting, authority submissions, and delegate supervision.

Head of Finance / CFO interim: experienced finance professionals who can ensure continuity of the finance function during leadership transitions — covering financial reporting, statutory accounts oversight, management reporting, and liaison with auditors and tax advisors.

Valuation Officer: specialists in independent asset valuation who can step into or reinforce the valuation function for fund structures — managing the end-to-end NAV process, pricing policy oversight, and coordination with external valuation agents, administrators, and auditors in line with AIFMD requirements.

ICT Officer / IT Governance Lead: experienced professionals who can assume or support the ICT governance function — covering IT risk management, DORA compliance, ICT third-party risk oversight, business continuity and disaster recovery frameworks, and IT-related regulatory reporting obligations.

ESG Officer: specialists in sustainable finance and ESG regulation who can step into or reinforce the ESG function — covering SFDR disclosure obligations, taxonomy alignment assessments, ESG data management, and integration of sustainability risk into investment and operational processes.

Other key functions: subject to availability, we can assess and deploy experienced professionals for additional functions within the entity’s operational and regulatory perimeter, based on the specific needs and urgency of the situation.

Secondment assignments under this service are structured to cover the full range of continuity scenarios — from urgent short-term placements following an unexpected departure to planned assignments of up to twelve months, providing the time needed to identify, recruit, and onboard a permanent successor without any gap in regulatory compliance or operational continuity.

Throughout the assignment, our seconded professionals operate with full accountability for the obligations of their role. They attend board meetings, engage with regulatory authorities, manage internal teams, and maintain the governance standards expected of the position — ensuring that the entity’s regulatory standing and internal culture are fully preserved from the first day to the last.

2. Operational Secondment — Experienced Professionals Across Functions

Beyond senior function holders, regulated entities frequently need to reinforce their operational teams — whether to manage a workload surge, cover a period of staff absence, or strengthen a team operating at the limits of its capacity. HACA Partners provides experienced operational professionals who integrate directly into the client’s teams, working under the direction of the client’s management and contributing immediately to day-to-day delivery across a broad range of disciplines.

These professionals are not junior resources — they are seasoned practitioners with demonstrated, domain-specific expertise, capable of managing complex tasks autonomously and producing structured, high-quality output from the outset of their assignment.

The areas in which we deploy operational secondees include:

Regulatory & compliance: ongoing compliance monitoring, regulatory change implementation, preparation of compliance reports and board dashboards, maintenance of policies and procedures, and support across MiFID II, AIFMD, and GDPR frameworks.

AML/CFT: KYC file review and remediation, investor due diligence, suspicious transaction monitoring, screening alert management, and preparation of AML board and authority reports — providing the RC function with the operational reinforcement it needs.

Valuation: support for the independent valuation process, NAV oversight, pricing policy application and review, coordination with external valuation agents, fund administrators, and auditors, and preparation of valuation committee materials.

Finance & accounting: management reporting, preparation and review of financial statements, coordination with external auditors, tax provision support, and assistance with regulatory financial reporting submissions.

Risk management: risk monitoring and reporting across market, credit, liquidity, and operational risk; stress testing and scenario analysis support; maintenance of risk registers and internal control frameworks; and preparation of risk committee and board reporting.

ICT & DORA compliance: IT risk assessments, ICT third-party provider monitoring, incident reporting procedures, business continuity and disaster recovery testing support, and assistance with DORA implementation and ongoing compliance obligations.

ESG & sustainable finance: SFDR periodic and pre-contractual disclosure preparation, taxonomy alignment reviews, ESG data collection and quality management, principal adverse impact (PAI) reporting, and integration of sustainability factors into investment and operational risk frameworks.

GDPR & data protection: data mapping and RoPA maintenance, data subject request management, privacy impact assessments, data breach notification support, and coordination with the Data Protection Officer.

Regulatory reporting: preparation and review of periodic regulatory submissions, including AIFMD Annex IV, MiFID II transaction reports, EMIR/SFTR trade reporting, CSSF questionnaires and surveys, and ESG-related disclosures.

Operational secondment assignments are structured flexibly — from short-term targeted reinforcements to longer-term embedded support — always with a clear scope, defined responsibilities, and the quality of delivery that HACA Partners’ clients expect. The secondee operates as a fully integrated member of the client’s team for the duration of the assignment, available on-site or on a hybrid basis as required.

The Edge We Bring

Independence

Our seconded professionals bring an external perspective that is free from the internal dynamics, relationships, and institutional pressures that can limit the objectivity of permanent employees. Whether holding a supervised function or reinforcing an operational team, they contribute an additional layer of professional independence — strengthening governance, improving the quality of outputs delivered to boards and regulators, and providing management with a credible, arms-length view of the entity’s compliance posture.
Expertise

Every professional we deploy has been selected for their depth of knowledge and hands-on regulatory delivery experience. Our supervised function holders are already CSSF-approved for equivalent roles — they know the regulatory framework, the CSSF’s expectations, and the governance standards required of their position from day one. Our operational secondees bring years of specialist experience across Luxembourg’s most demanding compliance disciplines. There is no ramp-up period — only immediate, credible contribution.
Plug-and-Play Readiness

The defining characteristic of our secondment service is operational immediacy. Our professionals arrive ready to fulfil their role — whether that means attending a board meeting as Conducting Officer on day one, managing a CSSF information request as Compliance Officer, or processing a KYC remediation backlog as an AML specialist. No lengthy onboarding, no regulatory delay, no learning curve on Luxembourg market practice. Just immediate, accountable, professional delivery.
Tailored Approach

We scope every secondment assignment carefully around the client’s specific situation — the nature and duration of the gap, the regulatory perimeter of the entity, the internal team’s dynamics, and the governance standards required. The professional we deploy is selected not only for their technical credentials but also for their ability to integrate effectively into the client’s environment and deliver results within the specific constraints of the assignment.
Quality & Continuity

HACA Partners remains accountable for the quality and conduct of every secondment throughout the assignment. Our professionals are supported by the broader HACA team, with access to collective expertise, peer review, and firm-level quality standards. Clients benefit not only from the individual deployed but from the depth of an entire practice — ensuring that the standard of delivery is consistent, reliable, and fully aligned with HACA Partners’ professional commitments from the first day to the last.