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New AML/CFT measures for unregulated Luxembourg Alternative Investment Funds

Tight filing deadline of the AED 2021 AML/CFT Questionnaire for unregulated investment funds in Luxembourg.

On 12 October 2022, the Administration de l’enregistrement, des domaines et de la TVA (“AED”) published an update on their website to enhance the visibility of key AML/CFT measures being put in place for Luxembourg alternative investment funds (“AIFs”) that are unregulated and not supervised by any other Luxembourg supervisory authority.

Key points:

  1. Luxembourg AIFs must submit an identification form applicable to their:
  • AML/CFT compliance officer (Responsable du contrôle du respect des obligations) (“RC”) ; and
  • the person responsible for compliance with the professional obligations as regards the fight against money laundering and terrorist financing (Responsable du respect des obligations) (“RR”).
  1. Luxembourg AIFs will need to submit to the AED, by 12 November 2022, their 2021 AML/CFT Questionnaire.

 

To support the above, the AED provided links providing guidance on both the Identification forms for RCs and RRs, as well as for the 2021 AML/CFT Questionnaire.

The AML Office is available to be your AML/CFT support partner by providing

  • Assistance with AML/CFT Questionnaires
  • An experienced and dedicated RC appointee
  • Assistance with the design and maintenance of the AML/CFT framework and documentation of your AIF
  • Provide mandatory annual AML/CFT training to the AIF Board

 

Please contact us to discuss your needs.

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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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