News Flash: CSSF CIRCULAR 15/612

On 6th of May, the CSSF released its Circular 15/612 relating to the information to be supplied by Luxembourg based AIFMs in relation to their unregulated AIFs established either in Luxembourg, in an EU Member State or in a third country (the “Unregulated AIFs”) and/or their regulated AIFs established in a third Country outside of the European Union (the “Regulated Third Country AIFs”).

In accordance with this circular, Luxembourg based AIFMs, whether approved or registered, shall report to the CSSF the name of each Unregulated AIF and of each Regulated Third Country AIF they currently manage as well as their investment strategies according to the forms provided. The reporting duty also applies to each newly set-up Unregulated AIF and Regulated Third Country AIF.

That duty should also apply to self-managed de minis Unregulated AIFs established in Luxembourg.

AIFMs shall inform the CSSF within 10 business days following the date on which they start their management activity. The starting date is the latter between the execution date of the management agreement or its effective date.

Conversely, they shall inform the CSSF within 10 business days following the end of their mandate.