Publication of a Newsletter by the AED relating to RAIFs and AIFs

On 27th January 2026, the Administration de l’Enregistrement, des Domaines et de la TVA – Registration Duty, Estate and VAT Authority (“AED”), being the supervisory authority in Luxembourg responsible for ensuring AML/CFT compliance by, inter alia, unregulated funds, issued a Newsletter with the aim of providing an overview of the situation of Reserved Alternative Investment Funds (“RAIFs”) and Alternative Investment Funds (“AIFs”), to highlight the main reporting issues for the year 2024, as well as to reiterate the key requirements for RAIFs and AIFs to cooperate with the AED.

Obligation to cooperate with the AED

In line with Article 5 of the Law of 12 November 2004 on the fight against money laundering and terrorist financing (“AML Law”) professionals (including RAIFs and AIFs) are required to cooperate with the Luxembourg authorities responsible for the fight against money laundering and terrorist financing, including the AED. In this respect, both RAIF and AIFs are reminded that:

The transmission of information and documentation, including the AML/CFT Questionnaire, RC Report and other legal documentation should be submitted within the specified deadlines of the AED;
The requested information and documentation should be communicated in an accurate, complete and up-to-date manner;
The information and documentation relating to material changes pertaining to the RAIF or AIF (such as liquidation, any change of RC or RR and/or information concerning them, etc…) should be communicated promptly; and
The information and documentation submitted to the AED should be retained and made available to the AED during an on-desk, or on-site inspection.

RAIF AML/CFT Reporting

Throughout last year’s RAIF AML/CFT reporting (including 2024 data), the below issues have been observed by the AED:

A delay in the submission of both the AML/CFT Questionnaire and RC Reports;
Missing or incorrect data within the AML/CFT Questionnaires, namely “Section 1 – Identification”; and
Missing information and other errors within the RC Reports, namely absence of a signature, an incorrect or missing RCS number of the RAIF, and a non-compliant file name format.

Going forward

Going forward, the submission of the AML/CFT Questionnaire and RC Report for RAIFs and AIFs must be done via separate emails as follows:

aed.raif@en.etat.lu – dedicated email address for RAIFs
aed.aif@en.etat.lu – dedicated email address for AIFs

With reference to the submission of the AML/CFT Questionnaire and the RC Report for RAIFs, the AED shall publish a specific communication on its website in February.

Furthermore, with reference to the AML/CFT reporting for AIFs, the AML/CFT Questionnaire and the RC Report shall be submitted exclusively upon invitation by the AED.

In view of the above, RAIFs and AIFs are strongly advised to regularly consult the AED’s website for updates.

Should you require further information, or clarifications on the above, or require assistance on the compilation of the AML/CFT Questionnaire and/or RC Report, kindly contact Natalia Hernandez and/or Jonathan Camilleri.