Global Trustee and Fiduciary Services Bite-Sized Issue 7 2025

AIFMD AFM Issues Sector Letter to AIFM-light Administrators On 30 June 2025, the Dutch Authority for the Financial Markets (AFM) issued a sector letter to all registered managers of alternative investment funds that fall under the registration regime (‘light managers’), pointing out a number of points for attention that emerged in a recent exploration of this group of managers. In the sector letter, the AFM shared its findings and its expectations. The AFM says that it has established that compliance with statutory obligations by light managers falls short on several points: • AIFMD reporting : reports are not always submitted in a timely or correct manner; • Key Information Documents are often missing or not provided (via a website); • AML and Sanctions Act : shortcomings in risk assessments and inadequate customer due diligence; • Investor classification : the distinction between professional and retail investors is regularly applied incorrectly; • Retail condition : light managers who make use of the “150 person condition” cannot sufficiently demonstrate how they meet it; and • Deregistration : Failure to deregister inactive managers or funds in a timely manner. The AFM emphasises in the sector letter that it is essential that light operators continue to comply with the applicable legal requirements. The sector letter offers concrete tools to test one’s own working methods against the expectations of the AFM. Therefore, the AFM says that it calls on all AIFM-light managers to carefully study the sector letter and – where necessary – adjust their business operations. The AFM adds that in October 2024, it published its AIFM-light Market View, in which the AFM outlines trends and risks within this fast-growing population. Link to AFM Sector Letter here (Dutch only) Investor Services Bite-Sized Global Trustee and Fiduciary Services QUICK LINKS Issue 7 | 2025 AIFMD CSDR ELIGIBLE ASSETS DIRECTIVE EMIR FINTECH FSB MIFID II/MIFIR SUSTAINABLE FINANCE/ESG VIRTUAL ASSETS ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM