AED RC report and AML/CFT questionnaire for RAIFs: what to file, who sends it, and which errors to avoid
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: 10 min read
Each year, a RAIF sends the AED two separate deliverables: the AML/CFT questionnaire (Excel, data as at 31 December) and the RC report (signed PDF) of its Responsable du Contrôle, the AML/CFT compliance officer. Both are due by 31 May, a date the AED confirms each year; for reference year 2026 the deadline is expected to be 31 May 2027.
This page is part of our guide to annual AML/CFT reporting for Luxembourg funds. A RAIF is supervised for AML/CFT by the AED (Administration de l'enregistrement, des domaines et de la TVA) even when its AIFM is CSSF-authorised: the AIFM is supervised by the CSSF, the RAIF by the AED. The AED states that the AIFM's compliance never exempts a RAIF from its own AML/CFT obligations. A RAIF therefore does not file the CSSF's SRRC, whose scope covers IFMs and some CSSF-supervised funds; see our SRRC guide for that report.
Key takeaways
- Each year, a RAIF sends the AED two separate deliverables: the AML/CFT questionnaire (Excel, data as at 31 December) and the RC report (signed PDF).
- Both are due by 31 May, close of business, a date the AED confirms each year; for reference year 2026 the deadline is expected to be 31 May 2027.
- The RR transmits the questionnaire and may mandate the RC to transmit it; the AED addresses its RC-report invitation to the RC.
- The AED RC report covers at least twelve topics, and the AED publishes no template.
- 768 of the 2,389 RAIF RC reports filed for 2024 were rejected; separately, the AED lists recurring errors, including a missing signature, a wrong or missing RCS number and a non-compliant file name.
On this page
- The AED RAIF AML/CFT questionnaire and the RC report: two deliverables, two formats
- AED deadline for RAIFs and where to send the files
- Who sends what: the RR, the RC and the board
- What the AED RC report must contain: the twelve topics
- Recurring errors the AED has flagged
- Prepare the data during the year, not in May
- How RC Insight helps
- FAQ
- Sources
The AED RAIF AML/CFT questionnaire and the RC report: two deliverables, two formats
The questionnaire and the RC report are two different deliverables, with two formats and two transmission rules. We recommend preparing and sending them as separate workstreams.
| Item | AML/CFT questionnaire | RC report |
|---|---|---|
| What it is | The annual AML/CFT questionnaire, with data as at 31 December | A summary report on the RC's AML/CFT activities and operation at the RAIF |
| Format | Kept in its original Excel format | Signed PDF, one single document; a scanned PDF is not accepted |
| Content | Set by the AED; a questionnaire that does not follow the AED guide is sent back | At least twelve topics listed by the AED; the AED publishes no template |
| File name | A set file name | "Name of the RAIF_RC_REPORT_<reference year>_DDMMYYYY.pdf", where DDMMYYYY is the date of transmission |
| Who sends it | The RR, who may mandate the RC to transmit it | The AED addresses its invitation to send the report to the RC |
| How | A separate e-mail, with no other file attached | By e-mail |
| Address | aed.raif@en.etat.lu | aed.raif@en.etat.lu |
| Deadline | 31 May, a date the AED confirms each year | 31 May, a date the AED confirms each year |
Is there an AED RC report template?
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" (final version, April 2025) for RAIFs and other unregulated AIFs. It has twelve chapters and states that it is not advice or official guidance. It is an industry template, not a rule. We recommend following the AED's list, in its order.
AED deadline for RAIFs and where to send the files
Both deliverables go to aed.raif@en.etat.lu by 31 May, close of business. For reference year 2025 the deadline was 31 May 2026. For reference year 2026, the deadline is expected to be 31 May 2027, a date the AED confirms each year. We review this date every January and September and update the "Last reviewed" line of this page.
The AED's January 2026 newsletter found that transmission of the 2024 questionnaires and RC reports was generally late. We recommend planning on the expected date without waiting for the confirmation.
AED-supervised RAIFs notify their RR and RC with the AED RR/RC identification form, at first appointment and after any change. Other unregulated AIFs follow a different regime: in 2026, their questionnaire and RC report were filed only on AED invitation, to aed.aif@en.etat.lu, and the RC report covers the same twelve topics as for RAIFs. Their case is covered in AED reporting for other unregulated AIFs.
Who sends what: the RR, the RC and the board
The AED texts assign transmission of the questionnaire to the RR, who may mandate the RC to transmit it, and address the RC-report invitation to the RC. For a RAIF, the RC is the main contact person for the AED, and usually files suspicious transaction reports via goAML, with the RR as fallback.
| Task | What the AED texts say | In our practice |
|---|---|---|
| Fill in the questionnaire | The RR or the RC; otherwise the person who filled it in must be officially mandated by the RR or RC | We recommend keeping that mandate in writing with the filing evidence |
| Transmit the questionnaire | The RR, who may mandate the RC to transmit it | Every communication with the supervisors stays under the RR's responsibility; the RR may mandate the RC to send it |
| Send the RC report | The AED addresses its invitation to the RC | Sent under the RR's responsibility; the RR may mandate the RC to send it |
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 LPEA industry template is likewise meant to be approved by the board/RR and then filed with the AED. The board side of the report is covered in the RC's annual report to the board.
What the AED RC report must contain: the twelve topics
The AED RC report covers at least twelve topics. They include the risk assessment, PEPs, asset due diligence, suspicious transaction reports to the CRF and breaches identified. The first column below follows the AED's list. The other columns are our recommendations, not AED requirements.
| Topic listed by the AED | What we recommend documenting | Where we suggest looking for the data |
|---|---|---|
| 1. The fund's exact name and RCS number | The legal name as registered, matching the file name and the questionnaire | The RCS extract |
| 2. Results of the ML and TF risk identification and assessment (what the two separate ML and TF assessments cover, national and international typologies), mitigating measures and risk tolerance | What each assessment (ML, TF) covers, the typologies, the conclusions, the measures and the tolerance approved by the board | The fund's ML/TF risk assessment, which in our practice is also attached to the report presented to the board |
| 3. Due diligence on customers, initiators, delegated portfolio managers and investment advisors, including ongoing monitoring | Who performed the due diligence (in-house or delegated), the files reviewed, the results | Transfer agent extracts, initiator and AIFM due diligence files |
| 4. Enhanced due diligence on intermediaries acting for their customers | The intermediaries identified, the enhanced measures applied and any gaps | The register of investors and the intermediary due diligence files |
| 5. Enhanced due diligence on PEPs | The PEPs identified, the approvals and how screening hits were cleared | Transfer agent screening reports and onboarding approvals |
| 6. Due diligence on the fund's assets | The checks on targets, sellers and counterparties, and the risk level assigned | Deal files and asset due diligence records |
| 7. Follow-up of positions blocked for AML/CFT reasons | Each blocked position, the reason for the block and the remediation steps taken | The transfer agent's blocked-account report |
| 8. Periodic review of all business relationships by risk level | The frequency set per risk level, the reviews completed and those overdue | The AML/CFT policy and the transfer agent's review tracker |
| 9. Results of controls on delegated tasks (and, where applicable, reasons for choosing new third parties during the year) | The controls per delegate, the findings, the choice of any new third party | Delegate due diligence questionnaires and board minutes |
| 10. Statistics on suspicious transactions reported to the CRF, with amounts | The count and amounts of reports, stated even when nil | The RC's own goAML records and internal alert log |
| 11. Statistics on transactions reported under financial sanctions, with amounts | The count and amounts of reports, stated even when nil | Sanctions screening logs, investor and asset side |
| 12. Number of breaches identified (state zero explicitly) | Each breach, its source, the corrective action and its status | The RC's findings log and the auditor's management letter |
For method on assets, see our guide to asset due diligence; for the wider picture, see the AML/CFT obligations of a RAIF.
Recurring errors the AED has flagged
The AED's January 2026 newsletter reports that 768 of the 2,389 RAIF RC reports filed for 2024 were rejected. Separately, it lists recurring RC-report errors, including a missing signature, a wrong or missing RCS number and a non-compliant file name. The newsletter does not state that these errors caused the rejections.
RC report: check before sending
- Signed PDF, one single document; a scanned PDF is not accepted.
- The fund's exact name and RCS number, correct and present.
- The file name in the AED's format: "Name of the RAIF_RC_REPORT_<reference year>_DDMMYYYY.pdf", where DDMMYYYY is the date of transmission.
Questionnaire: check before sending
- Kept in its original Excel format, with the set file name.
- Sent in a separate e-mail, with no other file attached.
- Filled in by the RR or the RC, or by a person officially mandated by the RR or RC.
- Completed in line with the AED guide: a questionnaire that does not follow it is sent back.
We recommend having these points checked by someone who did not prepare the files, for example the RR.
Prepare the data during the year, not in May
In our view, the quality of the report depends on what was recorded during the year.
- Keep a findings log from the start of the year.
- Agree early with the transfer agent on the year-end extract: investors, PEPs, risk ratings, blocked positions, screening hits.
- Update the risk assessment before drafting the report, since its conclusions feed topic 2 and, in our practice, it is attached to the report presented to the board.
- Reconcile the questionnaire figures with the statistics in the RC report before sending either.
- Book the board meeting that will see the report before the AED deadline.
The AED's own guide for RAIFs is summarised on our AED RAIF guide page. For a step-by-step back-plan and a data checklist, use the RC Annual Reporting Playbook 2027.
How RC Insight helps
RC Insight lets you prepare the AED questionnaire and RC report section by section in the platform, and track progress to submission. You collect the transfer agent's investor data through a secure upload and see the fund's investor base by country, risk level, PEP status and sanctions screening. You record each asset with its type, valuation, country and risk level. See the SRRC and AED report feature and our RC software page.
To plan the season, download the free playbook below. To see the reporting module in action, request a demo.
FAQ
When is the AED RAIF deadline for reference year 2026?
The AML/CFT questionnaire and the RC report are due by 31 May, close of business, a date the AED confirms each year. For reference year 2026, the deadline is expected to be 31 May 2027. Both go to aed.raif@en.etat.lu, the questionnaire in a separate e-mail.
What must the AED RC report contain?
The AED lists at least twelve topics: the fund's exact name and RCS number, the risk assessment, due diligence on customers, initiators, delegated portfolio managers and investment advisors, intermediaries, PEPs, assets, blocked positions, periodic reviews, controls on delegated tasks, suspicious transaction and sanctions statistics with amounts, and the number of breaches, stating zero explicitly.
Who sends the AED questionnaire, the RR or the RC?
The RAIF's RR transmits the questionnaire and may mandate the RC to transmit it, in a separate e-mail with no other file attached. The AED addresses its RC-report invitation to the RC. In our practice, every communication with the supervisors stays under the RR's responsibility.
Is there an official AED RC report template?
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" in April 2025, with twelve chapters. It states that it is not advice or official guidance, so it is an industry template, not a rule.
Can the questionnaire and the RC report go in the same e-mail?
No. The questionnaire is sent in a separate e-mail, with no other file attached, and kept in its original Excel format with a set file name. The RC report is a signed PDF, one single document, named "Name of the RAIF_RC_REPORT_<reference year>_DDMMYYYY.pdf", DDMMYYYY being the date of transmission; a scanned PDF is not accepted.
What errors does the AED see most often in RC reports?
In January 2026, the AED reported recurring RC-report errors, including a missing signature, a wrong or missing RCS number and a non-compliant file name. The same newsletter reports that 768 of the 2,389 RAIF RC reports filed for 2024 were rejected, without stating the reasons.
Sources
- AED, RC report for RAIFs: https://pfi.public.lu/fr/blanchiment/sf/fiar/rcreport.html
- AED, AML/CFT questionnaire for RAIFs: https://pfi.public.lu/fr/blanchiment/sf/fiar/aml-cft-questionnaire.html
- AED, guide to the RAIF AML/CFT questionnaire (version 03-2026): https://pfi.public.lu/content/dam/pfi/pdf/blanchiment/secteur-financier/guide-raif-aml-cft-questionnaire-version-03-2026.pdf
- AED, RR/RC identification form for RAIFs: https://pfi.public.lu/fr/blanchiment/sf/fiar/rr-rc-identification.html
- AED, RAIF guide (March 2023): https://pfi.public.lu/content/dam/pfi/blanchiment/2023/engl/mars/guide-version-032023-raif.pdf
- AED, newsletter of January 2026: https://pfi.public.lu/content/dam/pfi/pdf/blanchiment/news/newsletter-janvier-2026-fr.pdf
- AED, other AIFs (RC report and questionnaire): https://pfi.public.lu/fr/blanchiment/sf/fia/rcreport.html
- LPEA AML Expert Working Group, 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