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ARTICLE · 24 OCTOBER 2022

New AML/CFT Measures For Unregulated AIFs In Luxembourg

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The Luxembourg tax authorities (Administration de l'enregistrement, des domaines et de la TVA) (the "AED") as the supervisory authority of "other financial institutions" in accordance with the Law of 12 November 2004...

LuxembourgGovernment, Public Sector
Georgia Milne Aboitiz
Georgia Milne Aboitiz
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The Luxembourg tax authorities (Administration de l'enregistrement, des domaines et de la TVA) (the "AED") as the supervisory authority of "other financial institutions" in accordance with the Law of 12 November 2004 on the fight against money laundering and financing of terrorism, as amended (the "AML Law") has recently published new material on their website regarding the anti-money laundering and counter financing terrorism ("AML/CFT") supervision of unregulated Luxembourg alternative investment funds ("AIFs"), excluding reserved alternative investment funds ("RAIFs").

In line with the above, the AED has pronounced itself as follows:

  1. Obligation to appoint both AML RR and AML RC for all AIFs. The AED has published FAQs on the persons involved in AML/CFT for a Luxembourg AIF supervised by the AED for AML/CFT purposes, imposing such appointment. This appointment must be done by the management body of the AIF (i.e. board of the GP acting on behalf of the

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