New AML/CTF measures for all AIF supervised by the AED


In brief

The Administration de l'Enregistrement, des Domaines et de la TVA (AED) is stepping up in their Anti-Money Laundering and Counter Terrorist Financing (AML/CTF) supervisory role of Alternative Investment Funds (AIFs) and imposing new measures. The AED  has now clearly imposed on all AIFs under their supervision to appoint a person responsible for AML/CTF Compliance (Responsable du Respect or RR) and AML/CTF Compliance Officer (Responsable du Contrôle or RC).

In details

Each AIF under the AED supervision must now complete an AML/CTF Questionnaire by 12 November 2022. The AML questionnaire and the guidelines on how to complete it are available on the AED Website.

The questionnaire is identical to the RAIF AML/CTF questionnaire. It seeks to know per AIF:
  1. Who the RC and RR is; 
  2. Who the governing body is;
  3. Who the ultimate beneficial owner is;
  4. ML/TF risks identified; and
  5. Mitigating measures of these ML/TF risks,

The completion process is xls based and manual. 

This is a reminder to all that each investment fund, whether regulated by the CSSF (Part I and II Funds, SIF and SICAR) or overseen by the AED, now needs to have a full AML/CTF governance framework in place, which comprises: 
  1. Appointment of RR and RC;
  2. ML/TF Risk Appetite statement;
  3. ML/TF Risk Assessment;
  4. AML/CTF Policy; and 
  5. AML/CTF training. 

How PwC can help you

At PwC Luxembourg, we provide RC Support services to help you cope with the additional work. We also support you with our AML/CTF regulatory expertise as well as AML/CTF talent.