AED AML reporting for unregulated AIFs: SCSp, SCS and SCA funds
By the RC Insight team, practitioners who have helped more than 80 fund promoters set up their AML/CFT framework since 2020.
Published Last reviewed: 9 min read
AED AML reporting for unregulated AIFs concerns Luxembourg alternative investment funds that the CSSF does not supervise prudentially, such as unregulated SCSp, SCS and SCA funds: the AED supervises them for AML/CFT. In 2026, their questionnaire and RC report are filed only on AED invitation, yet the absence of an invitation does not exempt a fund from its legal obligations.
The AED is the Administration de l'enregistrement, des domaines et de la TVA, and AML/CFT stands for anti-money laundering and counter-terrorist financing. This guide is written for promoters and managers of unregulated SCSp (special limited partnerships), SCS (common limited partnerships) and SCA (partnerships limited by shares) who have never received a letter from the AED and want to know where they stand. It is part of our guide to annual AML/CFT reporting for Luxembourg funds, which maps each deliverable by type of entity.
Key takeaways
- The AED supervises unregulated Luxembourg AIFs, such as SCSp, SCS and SCA funds, for AML/CFT, and not only RAIFs.
- In 2026, the questionnaire and the RC report of other AIFs are filed only on AED invitation, to aed.aif@en.etat.lu.
- The absence of an invitation does not exempt a fund from its legal obligations, starting with an RR and an RC notified to the AED.
- The RC report covers the same twelve topics as for RAIFs: we recommend preparing it every year, invitation or not.
- For an SCSp whose general partner is its registered AIFM, in our practice an RC is appointed at both levels.
On this page
Which unregulated AIFs fall under AED AML/CFT supervision?
The AED supervises for AML/CFT RAIFs and other Luxembourg AIFs not prudentially supervised by the CSSF, for example unregulated SCSp, SCS and SCA AIFs. Its competence rests on Articles 2-1(8), 1(3a)(e) and 2(1) point 7 of the AML Law. "Unregulated" describes the absence of prudential supervision by the CSSF, not the absence of AML/CFT supervision.
The table below sorts the most frequent cases.
| Your fund | AML/CFT supervisor | Main AML/CFT reporting deliverable |
|---|---|---|
| SIF, SICAR, Part II UCI, UCITS or ELTIF | CSSF | SRRC, within five months after the closing of the annual accounts, exclusively via eDesk, when no Luxembourg IFM files on the fund's behalf |
| RAIF | AED | AML/CFT questionnaire and RC report, due by 31 May, a date the AED confirms each year |
| Unregulated SCSp, SCS or SCA that is an AIF | AED | AML/CFT questionnaire and RC report, filed in 2026 only on AED invitation |
The CSSF track is covered in our guide to the SRRC under CSSF Circular 24/854, and the RAIF track in our guide to the AED RC report and questionnaire for RAIFs.
Whatever the vehicle, every Luxembourg investment fund subject to AML/CFT supervision must appoint both an RR and an RC. The RR (Responsable du Respect des obligations) is the person responsible for compliance at management level, and the RC (Responsable du Contrôle du respect des obligations) is the compliance officer, under Article 4(1) of the amended Law of 12 November 2004.
What the AED asks unregulated AIFs to file
The AED works with three documents for other AIFs: the AML/CFT questionnaire, the RC report, and the RR/RC identification form.
The AML/CFT questionnaire
The AED runs reporting campaigns for other AIFs, covering the questionnaire and the RC report. In 2026, the questionnaire is filed only on AED invitation, to aed.aif@en.etat.lu, with data at 31 December 2025. As for RAIFs, the questionnaire is transmitted by the RR, who may mandate the RC, in a separate e-mail.
The RC report
The RC report of other AIFs covers the same twelve topics as for RAIFs. The AED lists at least these twelve topics:
- the fund's exact name and RCS number;
- results of the ML and TF risk identification and assessment, mitigating measures and risk tolerance;
- due diligence on customers, initiators, delegated portfolio managers and investment advisors, including ongoing monitoring;
- enhanced due diligence on intermediaries acting for their customers;
- enhanced due diligence on PEPs;
- due diligence on the fund's assets;
- follow-up of positions blocked for AML/CFT reasons;
- periodic review of all business relationships by risk level;
- results of controls on delegated tasks and, where applicable, the reasons for choosing new third parties during the year;
- statistics on suspicious transactions reported to the CRF, with amounts;
- statistics on transactions reported under financial sanctions, with amounts;
- the number of breaches identified, with zero stated explicitly.
The report is a signed PDF, a single document sent by e-mail; a scanned PDF is not accepted and the AED sets the file name. The AED publishes no template for the RC report. The LPEA AML Expert Working Group published a "Template Annual AML/CFT Report of the RC" for RAIFs and other unregulated AIFs, which states that it is not advice or official guidance.
The RR/RC identification form
AED-supervised RAIFs and other AIFs notify their RR and RC with the AED RR/RC identification form, at first appointment and after any change. The form is sent without delay to AED.AIF@en.etat.lu for other AIFs (AED.RAIF@en.etat.lu for RAIFs), unsigned, as the completed fillable PDF in its original format. It is limited to 2 MB, a scan of the printed form is not accepted, and the signed board minutes or circular resolutions go with it.
| Item | RAIF | Other unregulated AIF |
|---|---|---|
| AML/CFT supervisor | AED | AED |
| Questionnaire | Annual, Excel, data as at 31 December | Filed in 2026 only on AED invitation, data at 31 December 2025 |
| RC report | Signed PDF, at least twelve topics | Same twelve topics; filed in 2026 only on AED invitation |
| Deadline | 31 May (close of business), a date the AED confirms each year | Filed in 2026 on AED invitation |
| Address | aed.raif@en.etat.lu | aed.aif@en.etat.lu |
| RR/RC identification form | AED.RAIF@en.etat.lu | AED.AIF@en.etat.lu |
Is an unregulated AIF exempt if the AED has not invited it?
No: the invitation triggers the filing, not the obligations. In 2026, the questionnaire and the RC report of other AIFs, with data at 31 December 2025, are filed only on AED invitation, to aed.aif@en.etat.lu. The absence of an invitation does not exempt a fund from its legal obligations.
Every Luxembourg investment fund subject to AML/CFT supervision must appoint both an RR and an RC, and the fund's obligations are its own. For RAIFs, the AED states that the AIFM's compliance never exempts the fund from its own AML/CFT obligations. The fund then notifies its RR and RC with the RR/RC identification form.
In our view, a fund that has not been invited should not read the silence as a waiver. The topics of the RC report are a practical list of what an RC should be able to evidence at any time, invited or not.
SCSp: RR and RC at two levels
In our practice, for an SCSp the RR sits at general partner level: the board of managers of the general partner acting collegially, or one of the managers.
In our practice, where the general partner is also the fund's registered (de minimis) AIFM, an RC must be appointed at both levels: the general partner as registered AIFM, and the SCSp. As a registered AIFM, the general partner is supervised by the CSSF for AML/CFT and falls within the SRRC scope. The SCSp itself, as an unregulated AIF, is supervised by the AED.
We cover who can hold each role in RR and RC of an SCSp and its general partner, and the wider duties of the fund in AML/CFT obligations of an unregulated SCSp.
Preparing AED AML reporting without waiting for the invitation
We recommend running the AED cycle every year as if the invitation were certain, so that an invitation never finds the fund unprepared. The steps below are RC Insight recommendations, not requirements set by the AED.
- Confirm the regime. Check that the vehicle is an AIF supervised by the AED and not by the CSSF, and record the reasoning in the AML/CFT file.
- Check the RR/RC identification form. The AED requires the form at first appointment and after any change, sent without delay. We recommend checking that the form on file with the AED still names the current RR and RC.
- Keep evidence by report topic. Organise the year's controls, due diligence files and statistics under the topics of the RC report, so that the report draws on records rather than memory.
- Write the RC report anyway. In our practice, for a RAIF the RC's annual report to the board is the same document as the RC report sent to the AED, with the fund's ML/TF risk assessment attached. We apply the same standard to the other AIFs supervised by the AED. The board then holds an approved report that can be sent as soon as the AED asks for it.
- Avoid the formal errors. Reviewing the RAIFs' 2024 filings, the AED's newsletter of January 2026 lists recurring RC-report errors: a missing signature, a wrong or missing RCS number and a non-compliant file name. It also reports that 768 of the 2,389 RAIF RC reports filed for 2024 were rejected. The same formal rules (signed PDF, no scan, set file name) apply to the RC report of other AIFs.
- Decide who sends what. The AED states that the RR transmits the questionnaire and may mandate the RC to do so, in a separate e-mail. In our practice, every communication with the supervisors stays under the RR's responsibility; the RR may mandate the RC to send it. We recommend recording that mandate in the board minutes.
- Watch the AED's page for other AIFs. We recommend checking the AED's page before each reporting season rather than assuming the invitation model will continue.
How RC Insight helps
RC Insight is software for the RC of Luxembourg investment funds. You plan the year's AML/CFT controls for each fund, record each test with its evidence, and follow findings to closure. You prepare the AED questionnaire and RC report and the CSSF report section by section in the platform, and track progress to submission. Every action is logged with its author and date, so you can show the board, the auditor or the supervisor who did what, and when.
If your fund has no RC yet, or you want to rethink how the RC function is organised for an unregulated AIF, talk to us about an RC for your fund.
FAQ
Do unregulated SCSps have to report to the AED for AML/CFT?
Yes, when the SCSp is an AIF that the CSSF does not supervise prudentially: the AED supervises it for AML/CFT, like RAIFs. In 2026, the questionnaire and the RC report of such funds are filed only on AED invitation, and the absence of an invitation does not exempt a fund from its legal obligations.
What if my unregulated AIF has not received an AED invitation?
The absence of an invitation does not exempt a fund from its legal obligations. The fund must still have both an RR and an RC, notified to the AED with the RR/RC identification form at first appointment and after any change. We recommend preparing the RC report every year so that an invitation finds it ready.
Where are the questionnaire and the RC report sent for other AIFs?
For other unregulated AIFs, the questionnaire and the RC report are filed in 2026 to aed.aif@en.etat.lu, only on AED invitation. RAIFs use aed.raif@en.etat.lu instead. The RR/RC identification form goes to AED.AIF@en.etat.lu for other AIFs and to AED.RAIF@en.etat.lu for RAIFs, as the fillable PDF, unsigned, with the signed board minutes.
Is the RC report of an unregulated AIF different from a RAIF's?
No: the RC report of other AIFs covers the same twelve topics as for RAIFs. These include the ML/TF risk assessment, due diligence on customers, initiators, portfolio managers and assets, PEPs, reports to the CRF, financial sanctions and the number of breaches identified, with zero stated explicitly.
Who sends the documents to the AED, the RR or the RC?
For RAIFs and other AIFs alike, the AED states that the RR transmits the questionnaire and may mandate the RC to transmit it, in a separate e-mail. In our practice, every communication with the supervisors stays under the RR's responsibility, and the RR may mandate the RC to send it. We recommend recording the mandate in the board minutes.
Does the AED publish a template for the RC report?
No, the AED publishes no template for the RC report. The LPEA AML Expert Working Group published a "Template Annual AML/CFT Report of the RC" for RAIFs and other unregulated AIFs, to be approved by the board or RR. It states that it is not advice or official guidance.
Does an SCSp whose general partner is its registered AIFM need two RCs?
In our practice, yes: where the general partner is also the fund's registered (de minimis) AIFM, an RC must be appointed at both levels, the general partner as registered AIFM and the SCSp. The general partner, as a registered AIFM, is supervised by the CSSF for AML/CFT. The SCSp, as an unregulated AIF, is supervised by the AED.
Sources
- AED, other AIFs (AML/CFT supervision): https://pfi.public.lu/fr/blanchiment/sf/fia.html
- AED, other AIFs, RC report: https://pfi.public.lu/fr/blanchiment/sf/fia/rcreport.html
- AED, other AIFs, AML/CFT questionnaire: https://pfi.public.lu/fr/blanchiment/sf/fia/aml-cft-questionnaire.html
- AED, other AIFs, RR/RC identification form: https://pfi.public.lu/fr/blanchiment/sf/fia/rr-rc-identification.html
- AED, RAIFs, RR/RC identification form: https://pfi.public.lu/fr/blanchiment/sf/fiar/rr-rc-identification.html
- AED, RAIF pages: https://pfi.public.lu/fr/blanchiment/sf/fiar.html
- AED newsletter, January 2026: https://pfi.public.lu/content/dam/pfi/pdf/blanchiment/news/newsletter-janvier-2026-fr.pdf
- CSSF Circular 24/854 (SRRC): https://www.cssf.lu/wp-content/uploads/cssf24_854eng.pdf
- LPEA, Template Annual AML/CFT Report of the RC (April 2025): https://lpea.lu/wp-content/uploads/2025/04/LPEA-AML-TC_Annual-RC-report-for-RAIF-and-AIFs-proposal-April-2025.pdf