On 16 December 2020, the Administration de l’enregistrement, des domaines et de la TVA (the “AEDT”) sent letters to reserved alternative investment funds (“RAIFs”) to request them to appoint, in accordance with article 4(1) of the law on the fight against money laundering and terrorist financing of 12 November 2004 (the “AML Law”), two persons responsible for compliance with anti-money laundering and counter terrorist financing obligations, namely a “responsable du respect” (the “RR”) and one “responsable du contrôle” (the “RC”).
Such request, as explained by the AEDT in its Q&A dated 14 December 2020, derives from the passing of the law of 25 March 2020 amending the AML Law. From that moment, the AEDT became the supervisory authority of, among others, RAIFs.
Such request is not something new for the Luxembourg fund industry as the CSSF requests the appointment of an RR and RC for investment funds and investment fund managers under its supervision.
The RR and RC must be identified through an identification form, which should be submitted to the AEDT via email at the following email address: AED.firstname.lastname@example.org.