Counter-Proliferation Financing: What Luxembourg’s IFMs Are Doing – and Where Gaps Remain
The Luxembourg supervisory authority (CSSF) recently completed a thematic review focused on counter-proliferation financing controls across five Luxembourg-based investment fund managers (IFMs).
The review targeted the specific risk that fund investments might be used to raise, move or make available economic resources that contribute to the >proliferation of weapons of mass destruction (WMD).
The CSSF examined exposure at asset level with emphasis on dual-use goods (DUGs) and investments in vessels, shipping and other transportation means.
The assessment considered risks linked to North Korea, Iran and non-country-specific sanctions regimes and was carried out in the context of FATF’s enhanced expectations on proliferation financing risk assessment and mitigation, together with Luxembourg’s Law of 19 December 2020 implementing restrictive financial measures.
EU’s 19th Sanctions Package Tightens the Noose on Russia’s Energy, Financial and Evasion Networks
The European Union’s 19th sanctions package, adopted on 23 October 2025, represents a major step up in tactical and structural pressure on Russia’s war economy.
The measures notably combine an unprecedented energy embargo with targeted financial restrictions (including the first explicit crypto measures), expanded trade controls against the military‑industrial base, and strengthened anti‑circumvention tools that reach third‑country enablers.
For financial crime practitioners, compliance officers and investigators, the package broadens the list of sanctioned counterparties, tightens transaction prohibitions, and expands mechanisms for identifying and disrupting opaque value chains such as the oil shadow fleet and offshore crypto conduits.
Luxembourg’s Fund Industry Swells to €5.95 Trillion as Supervisors Push Simplification Without Deregulation
A resilient fund ecosystem, sharpening competition with Ireland, and a cautious stance on centralized EU oversight: Luxembourg’s financial watchdogs outlined a market in transition, with tax receipts rising and supervisory philosophy firmly rooted in pragmatism.
CSSF Updates AML/CFT Market Entry Form: What Funds and IFMs Need to Know
The Commission de Surveillance du Secteur Financier (CSSF) has introduced targeted updates to the AML/CFT Market Entry Form (MEF) to streamline the collection of standardized information on money laundering and terrorist financing (ML/FT) risks.
The MEF remains mandatory for Funds that are or will be authorised (including ELTIFs, regardless of their AIF type) and for Investment Fund Managers (IFMs) that are or will be authorised or registered and supervised by the CSSF for AML/CFT purposes.
The changes refine when the form must be filed and what information is required, while reinforcing expectations around governance and timely submission.
FAQ to Applying International Financial Sanctions: Key Duties, Reporting and Operational Expectations
This article explains the main obligations for financial sector professionals operating under Luxembourg law when confronted with international financial sanctions.
It translates legal and supervisory requirements into practical steps firms must adopt to remain compliant, avoid enforcement action and limit operational disruption.
