In order to follow-up previous communication done in October 2022:
Please be aware that the Administration de l’Enregistrement et des Domaines (AED), i.e., VAT
Authority, is the supervisory authority on AML/CFT purposes for non-regulated funds: RAIF, and
other non-regulated vehicles (SCSp and SCS):
For the RAIF, communication in February 2023:
In order to comply with your regulatory obligations in compliance with the law of 12 November 2004
on the fight against money laundering and terrorist financing as amended (« AML Law »):
- You need to provide to AED a RC report in accordance with article 4(1) of the AML law
provided by the “Responsable du contrôle” or “RC” of the RAIF on the activity of the RAIF for
the financial year ending in 2022. Deadline: 31 May 2023.
Additionally, it means that you need to implement the following measures:
- Formalization of the appointment of the RR and a RC.
- Ensuring you have completed and transmitted the AML-CFT questionnaire.
- Designing an AML-CTF framework: AML-CTF Policy and procedures, risk assessment and risk appetite statement and due diligence measures.
- AML-CTF training as required by the legal framework.
More information and instructions can be found on the AED website under the following link:
For all other non-regulated vehicles (SCSp and SCS):
Please be ready and comply with your AML-CFT obligations:
- Draft your RC report in accordance with article 4(1) of the AML provided by the
“Responsable du contrôle” or “RC” of on the activity of the non-regulated vehicle, for the
financial year ending in 2022. - Formalization of the appointment of the RR and the RC.
- Completion and transmission the AML-CFT questionnaire.
- Designing your AML-CTF framework: AML-CTF Policy and procedures, risk assessment and risk appetite statement and due diligence measures.
- AML-CTF training as required by the legal framework.
DS Compliance can assist you in the compliance with your regulatory obligations.
Please contact Elisa Da Silva, mobile: +691 717 568.