We always knew that the Alternative Investment Fund Managers Directive (AIFMD) suffered from the "one size does not fit all" problem. When devising any new fund proposal it is vital to work through the AIFMD parameters – whether there is indeed an AIF and if so which entity is its AIFM and work through the sub-threshold issues for new start-ups. There is though one positively helpful initiative which was introduced by way of a separate Regulation (No. 345/2013) with effect from 22 July 2013 for European Venture Capital Funds. For sub-threshold AIFMs with venture capital funds, the Regulation may provide some useful assistance.
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