Key changes introduced by the Luxembourg law of 25 February 2021

The Luxembourg Parliament has adopted a law of 25 February 2021 (the “Law”) which notably amends the law of 12 November 2004 on the fight against money laundering and terrorism financing (the “2004 Law”). As part of the changes carried out to the 2004 Law, it can be noted that:

  • professionals are prohibited from holding numbered accounts/savings account and numbered safes;
  • professionals are required in all circumstances to identify the client and its beneficial owner(s);
  • the obligation for credit institutions and financial institutions, when dealing with politically exposed persons, to establish the origin of the wealth and of the funds of the clients and beneficial owners identified as politically exposed persons;
  • additional information requirements for the registration as virtual asset service providers (“VASP”); and
  • additional requirements for natural persons, where registration as a VASP require demonstration of professional honourability and adequate professional expertise.

Our specialists remain at your entire disposal to assist you in carrying out the necessary amendments to your documentation and for any questions you may have regarding the above.