EU anti-money laundering rulebook sets July 2027 deadline for Luxembourg fiduciaries

Eight months before the EU Anti-Money Laundering Regulation applies on 10 July 2027, its technical standards are taking shape and Luxembourg is amending its 2004 law, leaving fiduciaries and corporate service providers limited time to adapt.

Under AMLR, these duties move into a directly applicable EU regulation.

Standards head to Brussels

In early October 2026, the Anti-Money Laundering Authority (AMLA) finalised three draft regulatory technical standards (RTS) supplementing the regulation, known as AMLR. The texts define business relationships and occasional transactions, set customer due diligence measures and frame group-wide arrangements. AMLA has sent its final reports to the European Commission, which may still amend the drafts before publication in the Official Journal, and proposed a six-month transitional period once they enter into force. Loyens & Loeff noted in March that the due diligence drafts cover non-financial obliged entities as well as banks, and that firms should expect more specific information requirements and more documented rationale. In a communiqué dated 7 October, the CSSF highly recommended professionals to finalise their gap analysis and start preparatory work at compliance and IT level.

Beneficial ownership checks for fiduciaries

Trust and company service providers operate under the law of 12 November 2004 (on the fight against money laundering and terrorist financing) ; the text defines their activities, including the provision of a registered office or business address. In March 2026, the TCSP working group of the National Prevention Committee published version 3.0 of its guidelines for professionals supervised by the Administration de l’Enregistrement et des Domaines (AED), the Institut des réviseurs d’entreprises, the Ordre des experts-comptables and the bar associations. The guidelines remind firms to identify and verify both the customer and the beneficial owner, and state that a nominee director never counts as beneficial owner of a legal person, nor does a nominee shareholder through the shares held as nominee. Under AMLR, these duties move into a directly applicable EU regulation. For existing client files, Loyens & Loeff reported that AMLA does not expect every existing customer to be fully updated by July 2027, with high-risk customers reviewed first.

Transposition and readiness

While AMLR applies without transposition, the sixth directive, AMLD6, must enter national law. Bill 8695 amends the 2004 law to transpose into the national legislation Articles 8 and 9 of the directive. It designates the National Prevention Committee as national coordination mechanism, creates a legal basis for a national AML/CFT coordinator and requires a review of the national risk assessment at least every four years. The Chamber of Commerce issued its opinion on 6 May 2026. Readiness remains uneven. A PwC Luxembourg survey of financial institutions, published on 19 May 2026, found that 59% of respondents had not fully analysed the impact of the EU package and that 42% had no plans to update their AML operating model. The survey did not cover non-financial professionals such as fiduciaries.

“It is urgent for Luxembourg entities to get educated about the possibilities that technology offers to make AML/CFT future-fit,” said Claude Marx, Director General, Commission de Surveillance du Secteur Financier (CSSF).

Story generated by AI and proofread by Marc Auxenfants