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Luxembourg RAIFs – AED issues AML guidelines

Reserved Alternative Investment Funds (RAIFs) by their very nature are unregulated funds which have many of the features of the regulated specialised investment fund (SIF) or the investment company in risk capital (SICAR), but which are not subject to supervision of the Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier (CSSF).

 

However, RAIFs are subject to the law on the fight against money laundering and terrorist financing of 12 November 2004, as amended, and the Administration de l’enregistrement, des domaines et de le TVA (AED), in it’s capacity as the competent authority and supervisor of AML compliance by RAIFs has published an AML guide to better assist RAIFs in the implementation of their AML/CFT professional obligations.

 

The Guide describes the minimum requirements for RAIFs and sets out practical information, examples, checklists along with guidance on the AML questionnaire to be submitted to the AED.

The Guideline’s (French only) can be obtained here.

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David Whelan
David Whelan
David is an experienced business leader and investment funds professional with over 22 years’ experience having held senior management roles within global financial services businesses.
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