INTRODUCTION
The Law on Reserved Alternative Investment Funds dated 23 July
2016 ("RAIF Law")1,
introducing a new type of Luxembourg investment vehicle named
"Reserved Alternative Investment Fund" (in short
"RAIF"), entered into force on 1 August
2016.
The RAIF is regulated under the AIFMD2 and benefits
from the corresponding EU passport but is not supervised by the
Commission de Surveillance du Secteur Financier
("CSSF"), making it an attractive
vehicle from a time-to-market perspective.
The AIFMD, a managers' directive and a change of
paradigm
The AIFMD requires that authorised alternative investment fund
managers ("AIFMs") ensure that the
alternative investment funds ("AIFs")
they manage comply with the AIFMD product rules3,
irrespective of whether or not the relevant AIF is subject to a
product regulation.