On 12 October 2022, the Administration de l’enregistrement, des domaines et de la TVA (“AED”) updated its website to enhance the visibility behind several key AML/CFT measures being put in place for Luxembourg alternative investment funds ("AIFs") that are unregulated and not supervised by any other Luxembourg supervisory authority.
Key points:
- Luxembourg AIFs must submit an identification form applicable to their:
a) AML/CFT compliance officer (Responsable du contrôle) (“RC”) ; and
b) the person responsible for compliance with the professional obligations as regards the fight against money laundering and terrorist financing (Responsable du respect) (“RR”); - Luxembourg AIFs will need to submit to the AED, by 12 November 2022, their 2021 AML/CFT Questionnaire.
To support the above, the AED provided links providing guidance on both the Identification forms for RCs and RRs, as well as for the 2021 AML/CFT Questionnaire.
How Apex can support you:
- Assistance with AML/CTF Questionnaires
- Dedicated RC appointment
- ESG Aligned RC’s
- Assistance to design or review the AML/CTF framework of your AIF (AML/CTF policy/procedures, ML/TF own risk assessment, AML/CTF risk appetite statement)
- Provide the AML/CTF training for the Board as required by the legal framework
- ESG Compliance including SFDR and Taxonomy
Please contact us to find out how we can support your business.
