The AED has reminded all RAIFs that the deadline to transmit the RC summary report related to the financial year ended 31/12/2023 is the 31/05/2024.

The AED has also published, on its website, the minimal content of the RC summary report of RAIFs.


The AED has under its AML/CFT supervision the Luxembourg reserved alternative investment funds (RAIFs), being not prudentially supervised by the CSSF or any other Luxembourg supervisory authority. 

In practice

1. How to submit the RC Report?

The signed report in pdf format should be returned to the AED to the following email address:

Format of the name of the pdf file to be transmitted:
Name of RAIF_RC_REPORT_2023_DDMMYYYY(date of transmission).pdf


2. Which elements should the RC report cover ?

The RC report must cover at least the following points:

  • The correct name, including the corresponding RCS number of the RAIF;
  • The results regarding the identification, the assessment of the AML/CFT risks and the measures taken to mitigate them, as well as the tolerance level of the AML/CFT risk of the RAIF;
  • The results of due diligence measures performed on clients, initiators of the RAIF, portfolio managers to whom the management has been delegated, investment advisors, including the ongoing due diligence;
  • The results of enhanced due diligence measures performed on intermediaries acting on behalf of their clients, including the ongoing due diligence;
  • The results of enhanced due diligence measures on identified individuals as politically exposed persons (PEPs) under the provisions of article 3-2 (4) (d) of the AML/CFT Law;
  • The results of due diligence measures performed on the assets of the RAIF, including the ongoing due diligence;
  • The monitoring of blocked positions for AML/CFT purposes at the level of the registers of bearer shares of the RAIF and/or the intermediaries acting on the marketing of the RAIF;
  • The periodic review of any business relationship according to its risk level;
  • In case of delegation of tasks concerning professional obligations to third parties, the results of controls performed on the compliance of services made by these third parties, not only with the legal and regulatory provisions, but also with the contractual provisions, if appropriate, the reasons for which the RAIF has chosen new third parties during the year;
  • The statistical background of identified suspicious transactions, including the number of reports of suspicious transactions made by the RAIF to the Luxembourg Financial Intelligence Unit, the Cellule de renseignements financiers (CRF), as well as the amount of related funds;
  • The statistical background of reported transactions within the framework of financial sanctions regarding the terrorist financing as well as those linked to the implementation of the resolutions of the United Nations Security Council and the acts adopted by the European Union, as well as the amount of related funds; and
  • The number of noticed breaches of professional obligations on AML/CFT purposes. If this number is equal to nil, it must be specified explicitly.

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