Fund Distribution Alert 2020-03

Fund Distribution Alert 2020-03



Said Fihri

Partner, Head of Digital Assets Services

KPMG in Luxembourg


Liechtenstein: change of local AIFM law and ordinance

On 1 February 2020, the updated Liechtenstein law for alternative investment fund managers (Gesetz über die Verwalter alternativer Investmentfonds, or AIFMG) and the related ordinance (Verordnung über die Verwalter alternativer Investmentfonds, or AIFMV) became effective.

The update affects alternative investment fund managers (AIFM) marketing alternative investment funds (AIF) on a cross-border basis in Liechtenstein as follows:

a) Exemption from the AIFM passport notification process for specific EEA AIFM intending to market EEA AIF to professional investors in Liechtenstein.

AIFM as defined under AIFMD Article 3 (2), that are registered and permitted to market EEA AIF in their home Member State, are now subject to a simplified notification process for distribution to professional investors in Liechtenstein. 

b) Updates to the notification process for AIFM intending to market AIF to retail investors.

EEA and non-EEA AIFM may theoretically market AIF to the public in Liechtenstein — now subject to a specific application process based on the AIFM’s and/or AIF’s domicile, various eligibility criteria, and requirements such as appointing a local branch or depositary.

No changes were made to the current notification procedure for standard EEA AIFM distributing EEA AIF to professional investors in Liechtenstein.

Links to the updated documents, only available in German, can be found here:

Please feel free to contact us if you require any additional information.


Said Fihri
+352 22 51 51 7892

Stephanie Zedda
Senior Manager
+352 22 51 51 7271

Please note that any information provided is general in nature, is based on the latest publicly available information as analyzed on a best endeavor basis and does not constitute any specific legal opinion or advice.

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