AED ¦ Guide to the RAIF AML/CFT Questionnaire (Version 03-2026)

How the AED reads a RAIF’s AML/CFT questionnaire

Reserved alternative investment funds (RAIFs) are not authorised or supervised by the CSSF, but they are obliged entities under the Law of 12 November 2004 on the fight against money laundering and terrorist financing, and the AED is their AML/CFT supervisor. Its main off-site tool is an annual AML/CFT questionnaire, and the AED has published version 03-2026 of its guide to completing it. The guide explains, question by question, what the AED expects in the four sections of the questionnaire: identification, ML/TF risks, mitigating measures and terrorist financing. It closes with a clear warning that questionnaires which do not follow its recommendations, in particular on the drop-down lists and the figures for assets under management, will not be accepted and will be sent back.

Scope, liquidation and the reporting year

The questionnaire covers a full calendar year. A RAIF that started its liquidation in 2025 has to report for the period from 1 January 2025 until the start of liquidation, while a RAIF whose liquidation began before 2025 does not have to file for 2025 at all. Fund managers winding down a vehicle mid-year should plan for that partial-year filing.

Several field labels and the page footers still carry the previous year’s references, including assets under management “as of 31/12/2024”, training “in 2024” and a footer dated 5 March 2025. Firms should follow the reporting period that the questionnaire template itself sets and raise any doubt with the AED before filing.

Bastian Schwind-Wagner _Follow

"With almost nine in ten RAIF questionnaires rejected in the last campaign, the AED guide works best as a checklist every AIFM goes through before filing. Most errors are avoidable: R.C.S. data that does not match, a legal entity entered as beneficial owner, amounts with dots and decimals.

The points I would check first are the goAML set-up and the risk ratings. A RAIF that is not registered as principal entity through its compliance officer cannot report a suspicion in its own name, and an inherent risk rating that reflects controls instead of exposure answers the wrong question."

Identification: legal names, inception dates and who fills in the form

The first section identifies the RAIF and its AML/CFT set-up. The AED wants the precise legal name and the number as they appear in the Luxembourg Trade and Companies Register (R.C.S.), and the inception date of the fund, meaning its date of incorporation or creation, not the date of registration with the R.C.S. All cells are mandatory unless they turn grey, and red cells flag entries that need correction.

The questionnaire also asks whether someone other than the person responsible (RR) or the compliance officer (RC) completed it. If so, that person must be officially mandated by the RR or RC. In practice, many RAIF questionnaires are prepared by the AIFM, the administrator or a service provider, and a written mandate should sit on file before the form goes out.

The “governing body” is the body managing the RAIF, for example the board of directors or managers of its general partner. Up to six members are entered, using the legal representatives shown in the R.C.S. Errors in this section are common. In January 2026 the AED reported that almost 90% of the 2024 questionnaires it received were rejected, most of them because of mistakes in Section 1.

RR, RC and beneficial owners

The RR (“responsable du respect”) is the person or body responsible for compliance with AML/CFT obligations at management level. Where the governing body itself holds that role, the RAIF names one member as contact for the AED and lists the other members in the comment column. The RC is the compliance officer, and the questionnaire asks for the country of residence of both, along with a series of yes/no questions on their role.

For beneficial owners, the guide restates Article 1(7)(a) of the AML/CFT Law: any natural person who ultimately owns or controls the entity through more than 25% of the shares or voting rights, or, where no such person is identified, the natural person who holds the position of senior managing official. At least one beneficial owner must be named, and it must be a natural person. The AED gives a typical example: one member of the board of the general partner is entered as beneficial owner and the others are listed in the comment column. Entering the general partner, the AIFM or a holding company does not meet the requirement.

goAML registration through the AIFM’s compliance officer

Every RAIF has to register on the goAML platform so that it can file suspicious transaction reports with the Cellule de Renseignement Financier (CRF). Many RAIFs have no staff of their own, so the guide allows registration through the compliance officer of the AIFM, under two conditions. The AIFM’s RC must also be appointed as RC of the RAIF, and that person must register on goAML as reporting proxy (“déclarant mandataire”) and, once the CRF agrees, register the RAIF as principal entity (“entité mandante”). The RC can then file reports with the CRF in the name and on behalf of the RAIF.

A registration made only at AIFM level, without the RC appointment at RAIF level and the proxy arrangement, does not satisfy the requirement. A RAIF that has never been set up as principal entity on goAML cannot report a suspicion in its own name, and the CRF expects reports and answers to its information requests without delay.

ML/TF risk data: advisors, investors and assets under management

The second section collects the data the AED uses to build its own risk picture of the RAIF. “Advisors” means investment advisors only, not legal or tax advisors. Where investors or related parties come from other countries, the jurisdictions must be named, and the RAIF has to say whether it has identified investors from higher-risk countries, which the guide describes by reference to FATF lists and reports from regulatory bodies.

Figures follow strict formatting rules. Assets under management and other amounts are entered in euro, without decimals, commas or dots, so one million is written as 1000000. Assets under management means the total market value of the investments managed on behalf of investors, and net asset value means total assets minus total liabilities. Percentages for the investment strategies are entered without the percentage sign and must add up to 100%. If the predominant strategy is “Other”, a description is mandatory, and a RAIF that invests in dual-use items must give further details.

Inherent risk, not residual risk

The questionnaire asks the RAIF for its own assessment of its money laundering risk and, separately, of its terrorist financing risk. The guide is explicit that both refer to inherent risk, meaning the risk before mitigating measures. A RAIF that reports a “low” rating because its controls are good has answered a different question. An inherent rating should also be consistent with the risk data reported elsewhere in the form, such as investor jurisdictions, strategy and asset classes; a low rating next to high-risk investors or dual-use exposure is likely to prompt questions.

Mitigation: training, sanctions screening and blocked positions

The third section covers the measures in place. Training questions use the definition of “employees” in Article 4(2) of the AML/CFT Law, which includes the members of the management bodies and the effective direction. For a RAIF, that includes the board members of its general partner. The RAIF must also confirm whether AML/CFT due diligence is carried out on its investments, which is the asset side of the fund’s ML exposure and often the weaker part of its controls.

Targeted financial sanctions appear in several places. The RAIF reports how often its TFS lists are updated and whether it holds positions blocked because of AML/CFT deficiencies. If it does, it must state the legal basis, meaning the article breached, the number of blocked positions and the value of the assets concerned, and say whether any blocked positions are affected by targeted financial sanctions. Further questions concern AML/CFT reporting, oversight of service providers and the RAIF’s own assessment of the quality of its AML/CFT organisation.

Terrorist financing: NPOs, the VRA and politically exposed persons

The fourth section focuses on terrorist financing. It asks about exposure to high-risk TF activities and sectors, including the number of domestic non-profit organisations and charities among the RAIF’s counterparties and the value of the assets concerned, and which actors within those NPOs were involved. The RAIF must say whether its procedures contain a dedicated TF section and which sources it uses for its TF risk assessment.

Two national sources are named. Questions on the TF vertical risk assessment ask whether the RAIF relies on it and where it was downloaded, and questions on the national risk assessment ask which version or year is used. A RAIF still working from an outdated NRA will show it here. The section closes with questions on how politically exposed persons are identified and whether the origin and source of wealth is established for investments made by NPOs, charities, trusts, foundations or similar legal arrangements. For the types of entities concerned, the guide points to the FATF’s work on legal persons and legal arrangements.

Getting the questionnaire accepted

A questionnaire that does not follow the drop-down lists or the formatting rules for amounts goes back to the sender. Given the rejection rate of the last campaign, RAIFs and their AIFMs should give the form the attention of any other supervisory filing: one owner for the questionnaire, a cross-check of Section 1 against the R.C.S. extract, a named natural person as beneficial owner, a working goAML principal-entity registration, inherent risk ratings that match the reported risk data, and evidence of board-level training.

The questionnaire also tells the AED a good deal about the money laundering risk of the RAIF itself: who the investors are and where they come from, what the fund invests in, whether investment due diligence takes place and whether the fund can report a suspicion at all. Incomplete or inconsistent answers on these points are what a supervisor is likely to pick up first.

Dive deeper

• AED ¦ Guide to the RAIF AML-CFT Questionnaire – Version 03-2026 ¦ Link