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  4. Luxembourg unregulated AIFs: Key AML compliance obligations and deadlines

Luxembourg unregulated AIFs (not restricted to RAIFs only): Key AML compliance obligations and deadlines

16 Apr 2025
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The Registration Duty, Estate, and VAT Authority (AED) has clarified that all Alternative Investment Funds (AIFs), including unregulated AIFs and not limited to RAIFs only, are required to comply with the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) reporting obligations. These requirements go beyond Reserved Alternative Investment Funds (RAIFs) and apply broadly to all AIFs under AED supervision. The AED has also provided guidance on determining if an entity meets the definition of an AIF and therefore falls within scope of the Luxembourg AML Law of 2004. This guidance can be found on the AED’s website.

Here's what you need to know to meet your obligations effectively.

Key reporting requirements

Unregulated AIFs must prepare and submit the following key documents for the 2024 reporting period by 30 June 2025:

AIF RC and RR Identification Form

  • Confirms the appointment of both a Responsible for Compliance (RR) and a Responsible for Control (RC).
  • Submit the original Excel format to AED by email. Ensure supporting governing body documents (eg, board minutes) are included.

AIF AML/CFT Questionnaire 2024

  • Provides a comprehensive overview of your fund’s AML/CFT compliance framework, with data as of 31 December 2024.
  • The questionnaire must be submitted in the original Excel format by the RR (or RC, if delegated).

Annual RC Report

A signed, PDF-format document summarising AML/CFT activities and compliance measures implemented by the RC as of 31 December 2024.

Where to access the documents

Detailed instructions and required forms are available on the AED website:

  • AIF RC RR Identification Form and FAQ guidance here.
  • AIF AML/CFT Questionnaire 2024 and completion guidelines here.
  • Information on preparing the Annual RC Reporthere.
Compliance is mandatory

Even if you do not receive a formal reminder, all AIFs must submit these documents in line with Articles 4(1) and 5 of the AML/CFT Law. Non-compliance can result in regulatory consequences, so ensure submissions are accurate, complete, and timely. For any questions, AIFs can contact AED directly at AED.finvehicles@en.etat.lu.

For further information, the official publication can be found here.

Authors
Vanessa Molloy Harneys front portrait image on a grey background
Vanessa Molloy
Partner | Funds & Regulatory | Luxembourg