AIFMD: Big Bang Or Damp Squib?

So it's here! After all the controversy, the Alternative Investment Fund Managers Directive (AIFMD) was implemented on 22 July 2013. At least it was partially implemented. As a European Directive, Member States of the EU (and the additional EEA states of Norway, Liechtenstein and Iceland) were required to transpose the Directive into national law by that date. In fact, only a minority of Member States have passed the laws necessary to implement the Directive, others have only draft legislation still to be put before their legislative bodies, and yet others appear to have done nothing at all.

National Private Placement Regimes

It is our understanding that where the Directive has not yet been implemented by national law, it has no application, and the pre-22 July 2013 status quo will continue until the national law is amended (even if this puts the Member State in breach of European law).