Is a RAIF supervised by the CSSF?
The RAIF itself does not require prior product authorisation by the CSSF. That does not mean it operates without a regulatory framework. A RAIF must appoint an authorised external alternative investment fund manager (AIFM), which is subject to supervision and reporting obligations.
Who may invest?
A RAIF is restricted to “well-informed” investors as defined by Luxembourg law. This encompasses institutional and professional investors and certain other investors meeting specified conditions. It is not a general retail fund simply because it has a Luxembourg domicile.
Typical operational building blocks
- An authorised external AIFM with portfolio and risk-management responsibilities under the applicable rules.
- A Luxembourg depositary and central administration in Luxembourg.
- Offering documents, an annual audited report and other applicable disclosures.
- Legal, audit, tax and administration specialists depending on the structure.
Where caution is needed
The intended asset classes, risk profile and distribution rules must be assessed individually. A RAIF’s lack of direct CSSF product authorisation must be communicated accurately; it must not be presented as a sign of CSSF approval of the fund.