2026 RAIFs AML/CFT Reporting

Today, 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, launched a campaign to invite all Reserved Alternative Investment Funds (“RAIFs”) to populate and submit specific documents as part of the AML/CFT supervisory measures adopted by the AED towards RAIFs.

The main purpose of this news item is to prompt RAIFs of the obligation to submit the below-mentioned three documents by 31^st May 2026 to the AED via the following email address: aed.raif@en.etat.lu.

RAIF RC RR Identification Form
2025 RAIF AML/CFT Questionnaire
2025 Annual RC Report

The information to be disclosed within the 2025 RAIF AML/CFT Questionnaire and 2025 Annual RC Report should include data and activities carried out by the RAIF as of 31^st December 2025. Furthermore, these two reports should include accurate information on the RAIF’s RCS number as well as its full name and details.

With reference to the submission of the RAIF RC RR Identification Form, the AED specifies that this Form must be submitted in cases where it has been either not submitted previously, or there have been changes since the last submission, especially with regards to the name of the RAIF, or a new nomination of the person responsible for compliance with the professional obligations as regards the fight against money laundering and terrorist financing – responsable du respect (“RR”), or the AML/CFT Compliance Officer – responsable du contrôle (“RC”).

Further insight on each of the above-mentioned documents can be obtained through the AED’s website via a specific section relating to Luxembourg RAIFs.

In view of the above reporting requirements, RAIFs should have in place a robust AML/CFT framework, inter alia including; (i) an effective AML/CFT policy and procedures, (ii) comprehensive AML/CFT risk assessments including information on risks included in the national and supranational risk assessment, and as communicated by other supervisory authorities, (iii) knowledgeable RR and RC, and (iv) key information relating to AML/CFT compliance from delegates, to ultimately ensure full compliance with the above.

Should you require any clarifications on the above, or require assistance in the compilation of the above mentioned three documents, or any other document forming part of the internal AML/CFT framework, kindly contact Natalia Hernandez or Jonathan Camilleri.