On 20 December 2019, Luxembourg's financial regulator, the
Commission de Surveillance du Secteur Financier (the
"CSSF"), published CSSF circular 19 / 7321 (the
"Circular") regarding clarifications on the
identification and verification of the identity of ultimate
beneficial owners ("UBO"). The Circular aims to
provide guidance to all professionals subject to the AML / CFT
supervision of the CSSF (the "Professionals") on the
practical implementation of UBO identification requirements and
verification measures.
Specifically, the Circular addresses: (i) the UBO identification
requirements for customers of Professionals that are natural
persons, legal persons or legal arrangements, (ii) the measures to
be taken to verify the relevant UBO's identity and (iii)
certain indicators that may help detect potential concealment of
beneficial ownership information. A number of Financial
Action Task Force ("FATF") reports and guidance documents
are also incorporated into the
