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Luxembourg's fund industry has long relied on external portfolio managers and investment advisors, but recent regulatory scrutiny raises fundamental questions about how investment decision-making is organized and where authority truly resides. The distinction between delegation and advisory models is not merely formal—it reflects a deeper tension between commercial reality and regulatory expectations, with direct consequences for sponsors seeking to maintain control while meeting substance requirement

At the time of its introduction, the RAIF was eagerly anticipated by participants in the Luxembourg fund industry.