Published on 23 August 2018, the new CSSF Circular aims to fight against money laundering and terrorist financing applicable to investment fund managers and entities carrying out the function of registrar agent.
Jan mentioned that in order to future proof and ensure continuity in a hard BREXIT scenario - post March 2019 - some UK-based initiators have already decided to establish proprietary AIFMs in Luxembourg, or, driven by economies of scale, are actively negotiating with third party AIFMs to provide these services for existing and new raise funds, as under a delegation model. He believed that even post BREXIT, the fund initiator should still be able to provide portfolio management from the UK or elsewhere. He said; “The combination of a potential hard BREXIT scenario and the implementation of the Circular might be seen as challenging for fund initiators but is certainly a great opportunity for Luxembourg to demonstrate its infrastructure, experience and to provide efficient solutions to address managers concerns.”
Jan has extensive knowledge in structuring unregulated and AIFMD compliant alternative investment funds. He provides support in regulatory matters and assists developing fund services globally as part of Vistra’s Alternative Investments Board. Contact Jan to find out more.
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