The Law of 16 July 20191 ("Law") which came into force on 22 July 2019 introduces two amendments to the Law of 23 July 2016 on Reserved Alternative Investment Funds ("RAIF").

The first amendment clarifies that a RAIF incorporated under the form of an FCP2 ("FCP-RAIF") can be managed by a management company authorised in accordance with Chapter 15 of the UCI Law3 ("UCITS ManCo"). A UCITS ManCo appointed as management company of an FCP-RAIF must appoint an external alternative investment fund manager ("AIFM") if the UCITS ManCo is not also authorised to act as AIFM in accordance with the Law of 12 July 2013 on AIFMs.

The second amendment corrects an oversight in the original version of the Law in order to enable the unitholders of an FCP-RAIF to convert the FCP into a SICAV under the same conditions as those provided for under the Law of 13 February 2007 on specialised investment funds (SIFs).


1. See also the article " Securitisation and other EU Regulations: New Sanction powers" in relation to the Law of 16 July 2019 in this Newsletter.

2. "FCP" means fonds commun de placement or common funds.

3. "UCI Law" refers to the Law of 17 December 2010 on undertakings for collective investment, as amended.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.