AML/CFT supervision of non-regulated alternative investment funds (excluding RAIF) by the AED – Project Finance/PPP & PFI

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The Luxembourg Registration, Inheritance and VAT Administrationadministration of registration, domains and VAT Where “DEA“) has in the context of its fight against money laundering and the financing of terrorism (“AML/CFT“) supervision Luxembourg alternative investment funds being unregulated financial vehicles and not supervised by another Luxembourg supervisory authority (“Unregulated AIFs“).

In this respect, the EDA has recently added a specific section on its website concerning these non-regulated AIFs ( ). Indeed, the AED asks non-regulated AIFs to complete and file:

(i) an identification sheet relating to (a) the person responsible for monitoring compliance with AML/CFT obligations at the appropriate hierarchical level.compliance officer“or the”RC“) and (b) the AML/CFT professional compliance officer (in French “responsible for compliance with obligations” or the “RR“) (the “RR/RC form“) (; and

(ii) an annual AML/CFT Questionnaire covering the 2021 financial year (the “Quiz“) (

In order to complete the RR/RC form and the questionnaire correctly, the AED has published frequently asked questions and guidelines documents on its website.

Certain non-regulated AIFs have received a communication from the AED asking them to complete and file the RR/RC Form and the Questionnaire by 12 November 2022 at the latest. If you have not received such a communication, it is recommended to Anticipate the request from the AED and therefore prepare the RR/RC form and the questionnaire together and submit these documents in advance to the AED. In addition, the RR/RC Form must be sent to the DEA without delay in the following situations:

  • Initial appointment of the RC and/or RR of the unregulated AIF; and

  • Modification of the RR and/or the RC of the unregulated AIF.

As a general reminder, all Luxembourg investment funds and Luxembourg investment fund managers must establish an AML_CFT governance framework (AML_CFT policy, risk assessments, appointment of RR/RC etc.).

Olivier Sciales
Knight & Sciales

36-38, Main Street,
L1660 Luxemburg
Office: + 352 26 25 90 30
Fax: +352 26 25 83 88
Email: [email protected]
Twitter: @oliviersciales

The content of this article is intended to provide a general guide on the subject. Specialist advice should be sought regarding your particular situation.

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