International Sanctions Compliance In Luxembourg: Update On Recent EU Measures And CSSF Guidance

The last quarter of 2025 has brought several material changes to the international sanctions landscape that affect natural and legal persons established in Luxembourg, the most important of which are discussed below. In particular, following reactivation by the United Nations ("UN") of certain nuclear‑related measures against Iran, the European Union ("EU") responded with parallel measures and additional autonomous restrictions in September 2025 (I). In addition, on 23 October 2025, the EU adopted the 19^th package of restrictive measures directed at Russia, with a particular emphasis on energy, finance and anti‑circumvention measures (II).

At Luxembourg level, the Commission de Surveillance du Secteur Financier ("CSSF") issued Circular 25/896 to adopt the European Banking Authority ("EBA") Guidelines on internal policies, procedures and controls for sanctions implementation ("CSSF Circular 25/896") for certain regulated entities (III). On 3 November 2025, the