AED's AML guidelines for RAIFs

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 “AML Law”).

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 tool.

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.


Sandrine Périot


Regulatory & Consulting, Financial crime - AML/CFT services

Manfred Hoffmann


Investment Management


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