Anti-money laundering and countering the financing of terrorism

AML/CFT: Last week the Administration de l'Enregistrement, des Domaines et de la TVA (the AED) published an AML questionnaire (the AML Questionnaire), an RR/RC identification form (the RR/RC Identification Form) and guidelines (the Guidelines) for unregulated AIFs under its supervision.

All such AIFs are required to appoint a person responsible for AML/CFT Compliance (Responsable du Respect or RR) and AML/CFT Compliance Officer (Responsable du Contrôle or RC).

In addition, an AML Questionnaire must be submitted for each such AIF. This questionnaire is similar to the one applicable to RAIFs; topics include the identification of ultimate beneficial owners, the identification of ML/TF risks and the mitigation measures taken in respect of these risks.

The AML Questionnaire, the RR/RC Identification Form and the Guidelines are available here.