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LUXEMBOURG’S REGISTRATION DUTIES, ESTATES AND VAT
AUTHORITY, THE ADMINISTRATION DE L’ENREGISTREMENT, DES
DOMAINES ET DE LA TVA (THE “AED”), HAS
PUBLISHED A GUIDE ON PROFESSIONAL AML/CFT OBLIGATIONS FOR
LUXEMBOURG RESERVED ALTERNATIVE INVESTMENT FUNDS
(“RAIFS”) SUPERVISED BY THE AED FOR
AML/CFT PURPOSES (THE “GUIDE”).
As the relevant supervisory authority, the AED released the
Guide to guide RAIFs in meeting their professional obligations in
AML/CFT matters. The Guide is informational, and describes the
minimum AML/CFT obligations that RAIFs must meet.
The AED is the AML/CFT supervisory authority for RAIFs and other
unregulated Luxembourg funds covered by the law of 12 November 2004
on the fight against money laundering and terrorist financing (the
One task of the AED is to identify RAIFs – in particular,
their management body, RR (responsable du respect des
obligations), RC (responsable du contrôle du respect
des obligations) and ultimate beneficial owners – as
well as their AML/CFT risks and the measures they have implemented
to mitigate those risks.
The Guide provides useful general information around AML/CFT
(definitions, summary of professional obligations, etc.), in
addition to practical examples and checklists.
Relevant existing materials have been fully integrated into the
Guide, including forms, contact details and guidance on the AML
questionnaire to be submitted to the AED. It is thus a very handy
The Guide only applies to RAIFs; it does not apply to
unregulated funds. Unregulated funds that are not subject to a
product law remain subject to the AML Law, and must comply with
their obligations under it.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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