Luxembourg: Reporting requirement for AML questionnaire by AIFs (excluding RAIFs)
The Luxembourg’s Registration Duty, Estate and VAT Authority (AED), as the supervisory authority of the other financial institutions (autres établissements financiers) according to articles 2-1 (8), 1 (3a) e) and 2 (1) 7 of the Law of 12 November 2004 on the fight against money laundering and financing of terrorism, as amended (AML/CFT Law), is inviting the AML/CFT compliance officer (Responsable du contrôle) (RC) and the person responsible for compliance with the professional obligations as regards the fight against money laundering and terrorist financing (Responsable du respect) (RR) of all unregulated AIFs (excluding RAIFs) to complete and transmit the “AIF AML/CFT Questionnaire 2021” for the financial year ending in 2021 in accordance with article 5 of the AML/CFT Law.
The AIF AML/CFT questionnaire must be transmitted by the RR of the AIF to the AED. However, the RR can mandate the RC to transmit the questionnaire.
The questionnaire must be conducted on a yearly basis and the deadline for the submission of the AIF AML/CFT questionnaire for 2021 is 12 November 2022. The AED provides instructions on how to complete the questionnaire.
AED’s questionnaire and instructions can be found here.
In respect to RAIFs, the AED’s AML/CFT questionnaire and instructions can be found here.