AED or the Administration de l’enregistrement, des domaines et de la TVA is the supervisory authority in charge of ensuring compliance by the professionals not referred to in paragraphs 1 to 7 of AML Law 2004 with their professional obligations as regards the fight against money laundering and terrorist financing provided for in Articles 2-2 to 5 and their implementing measures.
In its mission of supervision and control in the fight against money laundering and the financing of terrorism (hereinafter “AML/CFT”), the AED has developed questionnaires for professionals falling within its field of AML/CFT competence.
The professional sectors concerned initially are:
- the real estate sector,
- accounting professionals, financial and tax advisors,
- companies and trust service providers.
Additionally non-regulated, not supervised by CSSF Investment vehicles are subject to AED supervision:
- Non-regulated AIFs
Now let’s figure out different types of questionnaires applicable to different legal forms of professionals in scope of AED regulation:
What’s new for AIFs?
- RR/RC identification form
Same as RR/RC identification form RAIFs. This means that each AIF has to appoint RC and RR as defined in accordance with the Law of 12 November 2004 on the fight against money laundering and terrorist financing coordinated version which defines clearly scope for AED and obligations of professionals subject to AED supervision.
- AML/CFT questionnaire
Same form as AML/CFT questionnaire for RAIFs and is provided in Excel format.
The deadline for submission of such AML/CFT questionnaire is 12 November 2022.
FUND AML will be happy to assist you as a service provider for fulfilment of your AML/CFT obligations.