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ARTICLE · 14 MARCH 2025

AML/CFT Compliance In Luxembourg: New Obligations For Funds

Goodwin Procter LLP
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Against the backdrop of reinforced European and international anti-money-laundering and countering the financing of terrorism (AML/CFT) requirements...

LuxembourgFinance and Banking
Codrina Constantinescu
Codrina Constantinescu
Céline Moille
Céline Moille
Philip Spilberg
Philip Spilberg

Against the backdrop of reinforced European and international anti-money-laundering and countering the financing of terrorism (AML/CFT) requirements, the Administration de l'enregistrement, des domaines et de la TVA (AED) has expanded reporting obligations for the 2024 financial year.

Previously, only Reserved Alternative Investment Funds (RAIFs) were required to submit reports issued by the responsable du contrôle du respect des obligations (RC). Now, this obligation applies as well to unregulated alternative investment funds (unregulated AIFs), whether they have appointed a fully licensed EU alternative investment fund manager (AIFM), a non-EU manager or AIFM, or a de minimis AIFM pursuant to article 3.2 of directive 2011/61/EU on alternative investment fund managers (AIFMD) as transposed into Luxembourg law. Internally managed unregulated AIFs are also caught by the new provisions.

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