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By means of this update, we would like to inform you of an important disclosure obligation which will apply as of 1 January 2018 to all managers (AIFMs) of alternative investment funds (AIF) which offer AIFs in the Netherlands and in other jurisdictions of the European Union. Please find below a summary of the key points:
1) AIFMs have to prepare a Key Investor Information Document (KIID) for each new AIF they are marketing after 1 January 2018 (also when the marketing already started prior to 1 January 2018 and continues after 1 January 2018) and provide this to investors prior to investing in the AIF. As a result, in the preparation phase before the marketing a KIID should be prepared by the AIFM.
2) The provision of the KIID to investors may take place by posting the KIID on the website, provided certain conditions are met (e.g. the investors have agreed to this route).
3) Also, existing investors in an AIF which was marketed prior to 1 January 2018 can only transfer their interests in the AIF to another investor in case the AIFM has prepared a KIID. As a result, AIFMs which want to facilitate the transfer of interests between investors after 1 January 2018 should already start...
Sourcing, production and pre-market authorisations
On 31 October 2017, Belgium has published the Royal Decree amending the current Royal Decree of 3 March 1992 on the marketing of nutrients and foodstuffs to which nutrients have been added.