The Luxembourg Registration Duty, Estate and VAT Authority (in French, l’administration de l’enregistrement, des domaines et de la TVA or “AED”) has under its anti-money laundering and counter financing of terrorism (“AML/CFT”) supervision Luxembourg alternative investment funds being unregulated and not supervised financial vehicles by any other Luxembourg supervisory authority (“unregulated AIFs”).

In such respect, the AED has recently added a specific section on its website regarding these unregulated AIFs ( Indeed, the AED requests the unregulated AIFs to complete and file:

(i) an identification form related to (a) the person responsible for the control of the compliance of the AML/CFT obligations at the appropriate hierarchical level (in French, “responsable du contrôle du respect des obligations” or the “RC”) and (b) the responsible for the compliance with the professional obligations as regards the AML/CFT (in French “responsable du respect des obligations” or the “RR”) (the “RR/RC Form”) ( ; and

(ii) a yearly AML/CFT Questionnaire covering the financial year 2021 (the “Questionnaire”) (

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

Certain unregulated AIFs have received communication from the AED asking them to complete and file the RR/RC Form and the Questionnaire by 12 November 2022 at the latest. In case you have not received such a communication, it is recommended to anticipate AED’s request and, therefore, to prepare the RR/RC Form and the Questionnaire together and to submit such documents in advance to the AED. In addition, the RR/RC Form must be transmitted to the AED without delay in the following situations:

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

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

Please feel free to contact our investment management team concerning the completion of the Questionnaire and the RR/RC Form or any further questions on this matter.