Luxembourg's investment funds sector is adapting to new
enhancements to the anti-money laundering (“AML”) and
counter-terrorist financing (“CTF”) framework, after
the Administration de l'enregistrement et des
Domaines et de la TVA (“AED”) announced
increased filing obligations for unregulated Alternative Investment
Funds (“AIF”). Per the Law of 12 November 2004 on AML /
CTF measures in Luxembourg (“AML Law”) the AED is the
financial crime supervisory authority of Luxembourg AIFs.
According to the requirements stipulated in the AML Law, AIFs
must appoint a person among the members of their management bodies
who is responsible for compliance with all AML / CTF rules and
regulations – a responsable du respect des obligations
(“RR”) – and also an individual at the
appropriate hierarchical level as the responsable du contrôle
du respect des obligations (“RC”). The RR can be the
Board of directors (“Board”) acting as a collegial body
or it can also be one of the members
