RBO's deadline is coming: is your investment fund compliant?

More than the end of summer holidays, 31 August will mark this year the end of the six-month transitional period provided by the Register of Beneficial Owners (RBO) law. By that date, all Luxembourg entities must have filed the required information on their beneficial owners with the Registre des Bénéficiaires Effectifs. To learn more about the RBO, read our eAlert summarizing its key aspects.

Such formality applies also to investment funds, whether regulated UCIs (SIF, SICAR), semi-regulated (RAIF) or non-regulated (SCS, SCSp).

Please note that entities are also required to keep this information, up-to-date and with supporting documents, at their registered office.

Entities failing to comply with their obligations could be held a criminally liable and exposed to fines ranging between EUR 1,250- to EUR 1,250,000-. It is also important to note that service provider might not automatically take care of the filing and it remains the responsibility of entities to ensure they are compliant.

Our dedicated RBO team and our investment funds team are at your disposal to answer any questions you may have on this topic.