RC Service for Luxembourg AIFs
2025 Update
The Administration de l’enregistrement, des domaines et de la TVA (“AED”) is the supervisory authority responsible for AML/CFT supervision of non-regulated Alternative Investment Funds ("AIFs").
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As per the AED’s guidelines, AIFs must appoint an RC and RR through a decision made at the level of its managerial body (board of the GP, board of managers) and defined an AML/KYC framework in accordance with the AML Law.
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In 2025 all Luxembourg based AIFs are also expected to provide AML reporting to the AED, consisting of the annual AML/CFT Questionnaire and the annual RC Report. Deadline for both reports to be submitted to the supervisory authority is end of June 2025.
For more information, please consult the AIF section on the AED’s website.
How we can help
OMEA Advisors provides RC/RR support services to help you cope with these additional requirements. We are particularly strong in supporting alternative investment funds, which make up the vast majority of our RC client portfolio.
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We have proven in-depth experience in working with CSSF and AED supervised funds and to act as RC for a broad range of different fund types, including RAIFs and AIFs with Luxembourg-based AIFMs as well as with AIFMs based abroad.
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Our team of industry experts is here to provide assistance tailored to your needs. We can take on the RC and/or the RR mandate - whereby an OMEA staff member will personally act on behalf of the AIF - or assist you and your team with specific deliverables like the creation of annual AML reporting, an AML Policy or an AML framework for your fund.
To discuss your company's RC needs please get in touch.
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To summarise, Luxembourg AIFs supervised by the AED now need to have the following in place:
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RR/RC appointment
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AML/CFT Policy
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ML/TF Risk Appetite Statement
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AML/TF Risk Assessment Report
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AML/CFT training program
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