Separately Managed Accounts in Luxembourg
A separately managed account is a single-investor mandate. One institution gives the manager capital under bespoke terms, and the assets are held for that investor alone rather than pooled with anyone else's.
Single-LP separately managed accounts with bespoke mandate parameters, dedicated reporting and side-letter-native operating workflows.
Luxembourg private funds are typically RAIFs, SIFs or SICAVs wrapped as SCSp partnerships, managed by an authorised or registered AIFM subject to CSSF supervision, with UCITS available for regulated cross-border retail distribution.
How separately managed accounts are actually run
SMAs are how large allocators buy access without accepting standard fund terms. The investor sets its own exclusions, concentration limits, reporting cadence and often its own valuation and data requirements. Each mandate is effectively a bespoke product the manager must operate exactly as written.
The cost is duplication. Every SMA adds a distinct set of rules to apply and a distinct report to produce, and doing that manually is what caps how many mandates a firm can carry. Reuben AI holds mandate parameters as structured constraints, so eligibility, limits and reporting follow the mandate automatically instead of being remembered.
Regulatory framework
Local structuring, tax and regulatory advice is the responsibility of the fund's counsel and administrator. Reuben AI does not provide legal or tax advice.
How Reuben AI supports Separately Managed Accounts in Luxembourg
What the manager has to keep straight
Mandate parameters
Exclusions, limits and eligibility rules held as data and checked against every candidate position.
Bespoke reporting
Reports produced in the investor's required format and cadence from the same underlying record.
Segregation
Assets, cash and performance kept distinct from pooled vehicles at every level of the record.
Breach detection
Limit and exclusion breaches surfaced as they occur rather than discovered at quarter end.
Lifecycle of a sma in Luxembourg
| Stage | Work | Record produced |
|---|---|---|
| Mandate agreed | Terms, exclusions and limits captured as structured parameters. | Mandate specification |
| Deployment | Candidate positions tested against the mandate before commitment. | Eligibility check record |
| Monitoring | Limits evaluated continuously as positions and valuations move. | Compliance history |
| Reporting | Investor-specific reporting generated on the agreed cadence. | Mandate report |
| Review | Mandate performance assessed against its own terms, not a pooled benchmark. | Mandate review pack |
| Governance and audit | Approvals, conflicts, valuation policy and investor consents recorded as they happen rather than reconstructed at audit. | Immutable decision log and evidence pack |
Stages describe the operating workflow. Statutory filings and local registration requirements are set by CSSF (Commission de Surveillance du Secteur Financier) and the fund's counsel.
Often confused with
A feeder routes an investor into a pooled master fund on the master's terms. An SMA holds assets for that investor alone on the investor's terms.
Co-invest is deal-specific and sits alongside a fund. An SMA is a standing mandate that spans many deals.
Common questions
What makes SMAs expensive to run?
Duplication. Each mandate has its own rules and its own report, so manual operation scales linearly with the number of mandates rather than staying flat.
Can mandate breaches be caught before reporting?
Yes, when limits are held as structured constraints and evaluated as positions and valuations change, rather than checked in a periodic review.
Can one team run SMAs and pooled funds together?
Yes. Both sit on the same operating layer, with segregation enforced at the record level and reporting driven separately.