Germany is currently busy implementing the Alternative Investment Fund Managers Directive 2011/61/EU ("AIFMD") into German domestic law. In July 2012, the German legislator published an initial discussion draft of the legislation implementing the AIFMD into domestic law, the German Investment Code (Kapitalanlagegesetzbuch, or "KAGB"). This initial discussion draft of the German Investment Code went further than required by the AIFMD (see our Client Newsletter dated August 6, 2012), particularly with regard to the application of the German Investment Code to non-EU alternative investment funds (AIF) and non-EU alternative investment fund managers (AIFM).

The initial discussion draft of the KAGB has now been revised. This Newsletter addresses the main changes made to this revised draft of the KAGB.