AML/CFT obligations: new reporting for unregulated AIFs and deadlines for RAIFs

On 25 February 2025, the Administration de l’Enregistrement des Domaines et de la TVA (the "AED") expanded the AML/CFT obligations, which were initially only required for Reserved Alternative Investment Funds (“RAIFs”) – specifically the RC report for AML/CFT purposes (the “RC Report”), and AML/CFT Questionnaire – to include Luxembourg alternative investment funds (“AIFs”) not regulated by the Commission de Surveillance du Secteur Financier (the “CSSF”). Additionally, the AED updated its website to display the submission deadlines for these documents, required for RAIFs.