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Luxembourg Funds & AML: October 2026 Monthly Brief

October regulatory developments point to a common theme: Luxembourg fund managers must be able to demonstrate that their controls work in practice, not only that policies and procedures exist. From white-label arrangements and delegated portfolio management to fund errors and future AML requirements, recent CSSF and AMLA publications highlight the importance of effective oversight, clear responsibilities and documented decisions.

By Diego Ofano 26 October 2026 6 min read

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Luxembourg investment fund compliance and AML regulatory updates for October 2026, covering CSSF, AMLA and AIFM requirements. Copy

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Illustration of a tokenised investment fund using distributed ledger technology to simplify the traditional transfer agent model.

Digital & Virtual Assets

Tokenized Funds: Could the Transfer Agent role be reduced?

Luxembourg’s new CSSF FAQ shows that the main limit to a fully tokenized fund may no longer be technology, but regulation.

6 October 2026 By Diego Ofano

Funds

Luxembourg Funds & AML - September 2026 Monthly Brief

September did not bring major changes to the Luxembourg fund framework, but several developments deserve attention from AIFMs, Conducting Officers, Compliance Officers and other fund professionals. The main topics were the notification of redemption suspensions, new rules on sustainability claims, Luxembourg’s first risk assessment on financial sanctions, and new cyber security alerts.

30 September 2026 By Diego Ofano

Funds

Private Credit stress and Luxembourg funds: what should be done now

The private credit market is starting to show signs of stress and Luxembourg is more exposed than it might seem at first sight. Surely, the problem does not start in Luxembourg. The loans are not made to companies in Luxembourg, and many of the investment managers are not based there either. In reality, the economic risk sits elsewhere.

21 April 2026 By Diego Ofano

Digital & Virtual Assets

Crypto exposure without a Crypto license: when indirect exposure becomes full exposure

A Luxembourg AIF can be fully exposed to crypto-assets. The AIFM, managing the fund, does NOT need to obtain a crypto-specific license. Not because of a compliance lack, but because of how the framework is currently designed. When approaching Crypto exposure in investment funds, the CSSF has drawn a clear line between direct and indirect exposure. In practice, that line might be more theoretical than real.

7 April 2026 By Diego Ofano

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About Fundiligence

Independent perspective for a complex industry.

Fundiligence is an independent specialist publication covering Luxembourg and European investment funds, regulation, governance, AML and related industry developments. Founded by Diego Ofano.

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