AIFMD CSSF Circular 15/612: Information To Be Communicated By Luxembourg Established AIFMs

On May 5 the Luxembourg Financial Supervisory Authority issued CSSF Circular 15/612, addressed to all managers of alternative funds subject to the 2013 legislation implementing the Alternative Investment Fund Managers Directive, regarding reporting on unregulated alternative funds, whether established in Luxembourg, another EU member state or in a non-EU jurisdiction, as well as alternative funds regulated outside the EU.

The circular applies to registered alternative fund managers under Article 3 of the 2013 law, those with less than €100m in fund assets or €500m where there is a minimum lock-up of five years, as well as to managers that are fully authorised under the legislation, when they begin to manage any additional alternative fund or sub-fund – one that has not been previously reported to the regulator – that is unregulated, or regulated outside the EU. It does not concern funds run by Luxembourg managers in other member states, which are already covered by