The Autoriteit Financiële Markten (AFM) recently announced the start of an investigation with respect to holders of a licence for the management of investment institutions who, on 22 July 2013, by operation of law obtained an AIFMD licence following the introduction of the AIFMD (Pre-AIFMD licence holders). In a (pre-announcement) letter the AFM indulged that this investigation will focus on rules with respect to governance, operational integrity and asset separation. It has come to our attention that the questionnaire which the AFM sends to selected Pre-AIFMD licence holders is quite extensive and contains detailed questions. Since the answers to the questions may trigger discussions on ongoing compliance, we strongly advise parties who receive such a questionnaire to seek legal advice.
To view a copy of the AFM news item: Click here.