As most fund managers who either market a fund into the European Union (EU) or manage certain EU funds now know, from July 22, 2013, the EU’s Alternative Investment Fund Managers Directive (Directive or AIFMD) will impact many non-EU managers in potentially significant ways. The preparation required can be significant. As a result, Hedge Fund Law Report is publishing this two-part series designed to help non-EU private fund managers understand the steps they must take to prepare for effectiveness of the AIFMD. The first installment focused on the impact of the Directive during the period from July 2013 through 2015 – the period that first article referred to as “Stage I,” during which non-EU managers will not be fully authorized under the Directive, but nonetheless can be subject to many parts of the Directive, depending on the scope of their activities touching the EU. See “Application of the AIFMD to Non-EU Alternative Investment Fund Managers (Part One of Two)
,” Hedge Fund Law Report, Vol. 6, No. 21 (May 23, 2013). This second installment focuses on what this article refers to as the Directive’s “Stages II and III,” which are due to come into effect in 2015 or later, which contemplate a transition to full authorization under the Directive by all fund managers that are subject to the Directive’s jurisdiction. The authors of the series are John Adams, counsel in the Asset Management Group at Shearman & Sterling LLP; Nathan Greene, a partner and Co-Practice Group Leader in Shearman’s Asset Management Group; Christian Gloger, a senior associate in the Group; and Christine Ballantyne-Drewe, an associate in the Group.