Marketing under the AIFM Directive covers any “direct or indirect offering or placement at the initiative of the AIFM or on behalf of the AIFM of units or shares in an AIF it manages to or with investors domiciled in the EU.” An AIF is defined as a collective investment undertaking, or compartment thereof, which raises capital from a number of investors, with a view to investing it in accordance with a defined investment policy for the benefit of those investors and which is not covered by the UCITS Directive. The marketing provisions of the Directive do not apply to passive.
