Rundschreiben CSSF 15/633

The European Union Authority for Anti-Money Laundering and Countering the Financing of Terrorism has finalised three sets of Regulatory Technical Standards...

The EU's third-country branch regime under CRD VI fundamentally changes how non-EU banks can serve European clients, requiring most institutions to establish authorized branches or subsidiaries by January 2027. With national transposition underway and a critical grandfathering deadline already passed, affected institutions must urgently assess their EU activities, evaluate available exemptions, and determine whether their current operating models remain viable under the harmonized framework.

Luxembourg's CSSF imposed a €56,000 fine on Stonehage Fleming Luxembourg S.A. for multiple compliance failures, including significant delays in processing sanctions screening alerts and implementing changes to screening lists. At the time of inspection, hundreds of alerts had been treated with substantial delays and 42 alerts remained completely unnoticed by the financial services provider.

On 23 September 2022, ESMA released an updated version of its Guidelines on certain aspects of the suitability requirements as provided for under Directive 2014/65 on Markets...

Two years on from the entry into force of Directive (EU) 2024/927, commonly referred to as AIFMD II, the 16 April 2026 transposition deadline has passed, and the state of play across the EU is best described as uneven, with compliance posture increasingly dependent on where an AIFM is authorised. However, Luxembourg, which hosts the largest shares of EU AIFs within the Union, transposed the Directive without material gold-plating.

The formal process of implementation of Directive (EU) 2024/1619 amending Directive 2013/36/EU ("CRD VI") began on 6 October 2025 with the publication of the bill of law n°8627 ("Bill") and its submission to Parliament.

The Luxembourg law of March 3, 2026 transposed the AIFMD II Directive into national law, introducing significant changes to the regulatory framework governing alternative investment funds. This article examines the practical implications for financing transactions involving Luxembourg AIFs, analyzing how the new rules on loan origination, leverage caps, concentration limits, and enhanced disclosure requirements affect both lenders and borrowers in structured finance arrangements.

Reverse solicitation remains one of the most scrutinised concepts in fund distribution, offering a legitimate route for investment when approached entirely on the investor's initiative. Yet the distinction between genuine unsolicited interest and marketing activity carries significant regulatory consequences, requiring AIFMs to navigate narrow fact-specific exceptions rather than treating it as a designed distribution model.

Luxembourg's partnership limited by shares (SCA) offers private fund managers a compelling corporate alternative to the special limited partnership structure, particularly for EU family offices and high-net-worth individuals. When combined with the RAIF regime, this vehicle achieves tax neutrality while maintaining the corporate governance framework that certain investors prefer. The SCA-RAIF structure addresses key legal and tax considerations while providing flexibility for secondary strategies, fund-of-f

On 29 August 2024, Luxembourg's CSSF issued Circular 24/860, clarifying governance, risk management, and audit committee requirements for credit institutions, updating key provisions of Circular 12/552.