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Iceland implements the Alternative Investment Fund Managers Directive (AIFMD)

4. September, 2020

Iceland has finally implemented the EU directive on Alternative Investment Fund Managers (AIFMD) with the enactment of Act no. 45/2020 which came into force this spring. Although the Icelandic regulator has in practice observed part of AIFMD’s provisions this is a much needed and pleasing step whereas comprehensive legislation is now applicable to AIFMs and AIFs in Iceland.

The new act applies to managers who operate or market one or more AIFs in Iceland or in other states within the EEA, regardless of the form of the manager, the form of the AIF and whether they are open-end or closed-end funds.

Those who intend to operate or market AIFs in Iceland are required to have an operating license or be registered with the Central Bank of Iceland. Whether a manager is subject to an operating license or a registration obligation depends on various factors, including the total assets under management of the relevant management company and whether the manager has an operating license in another EEA state or has been registered within another EEA state. Managers with an operating license and registered managers have the sole right to operate and market AIFs in Iceland.

Stefán Orri Ólafsson (, Partner at LEX, has in recent years provided advice to both domestic and foreign fund managers who have wanted to market their funds in Iceland and on other aspects in the field of Icelandic fund legislation.

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