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April 2025
The work presented herein is issued on behalf of the members of the LPEA AML Expert Working Group (the “Working Group”), who are professionals active in the field of anti-money laundering (“AML”) and counter-terrorism financing (“CTF”).
This paper aims to provide a suggested basis for the purpose of the yearly reporting of the compliance officer in charge of the control of compliance with the Anti-Money Laundering and Countering the Financing of Terrorism (“AML/CFT”) professional obligations (responsable du contrôle du respect – “RC”) to be approved by the board / responsible for compliance with the AML/CFT professional obligations (responsable du respect – “RR”) for the Luxembourg Reserved Alternative Investment Funds (“RAIF”) and other unregulated Alternative Investment Funds (“AIF”) (each a “Fund”). Such annual report shall be filed with the Registration Duty, Estate and VAT Authority (Administration de l’enregistrement, des domaines et de la TVA – “AED”), as national authority competent for AML/CFT supervision of Luxembourg non-regulated AIFs (i.e. the Funds).
Although this paper aims to be universal and meets AED requirements, it needs to be adapted to the Fund’s activities and the RC’s specific AML/CFT controls.
