An Investment Fund Manager (IFM, in French: “Gestionnaire de Fonds d’Investissement”) is a term introduced by the Luxembourg financial regulator (the Commission de Surveillance du Secteur Financier, CSSF), in its CSSF Circular 18/698 (the “Circular”). It designates the following entities: 

1. management companies incorporated under Luxembourg law and subject to Chapter 15 of the Law of 17 December 2010 relating to undertakings for collective investment (“2010 Law”) - in the Circular these entities are also referred to as “ManCos” as well as “IFMs”;

2. management companies incorporated under Luxembourg law and subject to Articles 125-1 or 125-2 of Chapter 16 of the 2010 Law; these entities are also referred to as “AIFMs” as well as “IFMs” in the Circular; 

3. Luxembourg branches of IFMs subject to Chapter 17 of the 2010 Law; 

4. investment companies which did not designate a management company within the meaning of Article 27 of the 2010 Law (referred to as “SIAGs” in the Circular); 

5. alternative investment fund managers authorised under Chapter 2 of the Law of 12 July 2013 on alternative investment fund managers (the “2013 Law”); these entities are also referred to as “AIFMs” as well as “IFMs” in the Circular; and 

6. internally managed alternative investment funds within the meaning of point (b) of Article 4(1) of the 2013 Law (the “FIAAGs”).

Reference : CSSF Circular 18/698 on Authorisation and organisation of investment fund managers incorporated under Luxembourg law and specific provisions on the fight against money laundering and terrorist financing applicable to investment fund managers and entities carrying out the activity of registrar agent; the Law of 17 December 2010 relating to undertakings for collective investment as amended and the Law of 12 July 2013 on alternative investment fund managers as amended.

*Podcast #238:

*YouTube Video 227|:

Bertrand Mariaux, Avocat à la Cour, LL.M. (hons.)

Prestation de serment (Swearing-in oath): Luxembourg (2011), Certificat d’Aptitude à la Profession d’Avocat, École de Formation professionnelle des Barreaux de la Cour d’appel de Paris (2009), Bond University (LL.M. (distinct.), International Legal Practice, 2010), Université Sorbonne Paris Nord & University of Limerick (Master in European & International Law - major in economics, 2008), certified Expert in Microfinance (Frankfurt School of Finance & Management, 2015), social entrepreneurship (University of Oxford, 2015 & The Wharton School of Social Policy & Practice, 2014) and social & solidarity economy (International Labour Organization Academy - Social & Solidarity Economy, Organisation Internationale du Travail - Économie Sociale et Solidaire, 2017)