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ARTICLE · 24 DECEMBER 2020

Luxembourg Update: Important Clarification For RAIFs For RR And RC Appointments

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The Luxembourg indirect tax authorities (the "ITA") have published a FAQ in relation to persons involved in AML / CFT for a Luxembourg reserved alternative investment fund ("RAIF")...

LuxembourgGovernment, Public Sector
Johan Terblanche
Johan Terblanche
Michelle Barry
Michelle Barry
Nelly Zhang
Nelly Zhang
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The Luxembourg indirect tax authorities (the "ITA") have published a FAQ1 in relation to persons involved in AML / CFT for a Luxembourg reserved alternative investment fund ("RAIF") supervised by the ITA2 for AML / CFT purposes (the "FAQ"). 

It clarifies that RAIFs are legally required to appoint two individuals responsible for AML / CFT:

  • a 'responsable du respect des obligation' ("RR"); and
  • a 'responsable du contrôle du respect des obligations' ("RC").

Background

On 25 November 2019, Luxembourg's financial regulator, the Commission de Surveillance du Secteur Financier ("CSSF"), published a similar FAQ3 in relation to Luxembourg funds and investment fund managers supervised by the CSSF for AML / CFT purposes. However, as RAIFs are not supervised by the CSSF, they did not fall within the scope of the FAQ.

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