In this context, the AED requests that the Person Responsible for Compliance with AML/CFT Obligations (Responsable du respect – “RR”) and the AML/CFT Compliance Officer (Responsable du contrôle – “RC”) of all unregulated Alternative Investment Funds (“AIFs”) not subject to a product law (e.g SIF, UCITS, SICAR etc) complete and submit the “AIF AML/CFT Questionnaire 2024”. This obligation is in line with Article 5 of the AML/CFT Law, which requires AIFs to cooperate with the authorities. 

Key deadlines 

  • Reference date for the questionnaire: 31 December 2024 
  • Submission deadline: 30 June 2025 (Close of Business)

Who must submit the questionnaire?  

The RR of the AIF is responsible for submitting the questionnaire. However, the RR may mandate the RC to submit it on their behalf.  

Format and transmission  

The questionnaire must be submitted in its original Excel format via email to: AED.finvehicles@en.etat.lu   

PDF or other file formats will not be accepted.  

Additional reporting obligations for unregulated AIFs  

It is important to note that this AED AML/CFT Questionnaire is separate from the AML survey required by the CSSF for the AIFMs of such AIF. All unregulated AIFs must be ready to also submit the following to the AED: 

  • A signed RC report 
  • The board approving the RC report.

Our investment management team is available to support your AIFs in reviewing and preparing their AIF AML/CFT Questionnaire 2024 and ensuring compliance with AED requirements. Don’t hesitate to contact us should you need our assistance.