Developed by the ABBL’s Depositary Banking Cluster and LPEA, these Guidelines on Look-Through and Control provide a harmonised framework for Luxembourg depositary banks under the AIFMD. They define criteria to assess control situations in alternative investment funds (AIFs), distinguishing between exclusive, joint, and risk-based control. The document clarifies when depositaries must apply look-through obligations for safekeeping and ownership verification, details escalation and monitoring procedures, and offers practical case studies across fund structures. By promoting consistent interpretation and compliance, these guidelines strengthen investor protection, operational clarity, and regulatory alignment within Luxembourg’s alternative investment ecosystem.
