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.