ESMA has published its final guidance on key concepts in the Alternative Investment Fund Managers Directive (AIMFD). The guidance includes ESMA’s views on what is meant by:

  • a collective undertaking;
  • raising capital;
  • a number of investors; and
  • a defined investment policy for the purposes of AIFMD.

Despite several respondents asking for further clarification as to whether joint ventures and commercial special purpose vehicles should fall outside AIFMD scope, ESMA made few changes from its consultation draft. (Source: ESMA Publishes Final AIFMD Key Concepts Guidance)