Communication on new AML-CFT regulatory requirements applicable to all non-regulated AIF: deadline on 12 November 2022.

On 12 October 2022, the Administration de l’Enregistrement et des Domaines (AED), i.e. VAT Authority and AML-CFT supervisory authority in Luxembourg, has extended the AML-CFT obligations applicable to the RAIF to all AIF, non-regulated by the CSSF but supervised by the AED. All non-regulated AIF need to comply with the same AML-CFT obligations as any fund in Luxembourg, i.e.:
  • Appointment of the RR and a RC.
  • Completion and transmission of the AML-CFT questionnaire by 12 November 2022.
  • Designing the AML-CTF framework i.e. AML-CTF procedures, risk assessment and risk appetite statement.
  • AML-CTF training to the Fund Board 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.