Upcoming AML/KYC Changes for Investment Funds in Luxembourg in 2025
Significant changes are approaching Luxembourg’s investment funds sector regarding Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations in 2025. These updates aim to bolster the integrity and security of the financial system, making compliance essential for firms.

1. Implementation of CSSF Circular 24/856
Implementation of CSSF Circular 24/856 The Commission de Surveillance du Secteur Financier (CSSF) will implement Circular 24/856 on January 1, 2025. This circular revises the rules for Net Asset Value (NAV) oversight and compliance, replacing Circular 02/77. Consequently, investment firms in Luxembourg must review and adjust their current policies and procedures to meet the new requirements and ensure compliance by the effective date.
2. Establishment of the Anti-Money Laundering Authority (AMLA)
The European Union will establish the Anti-Money Laundering Authority (AMLA) with its regulations becoming effective on July 1, 2025. AMLA will function as a central authority overseeing AML/CFT compliance across EU member states, including Luxembourg. Its role will include direct supervision of selected entities and coordination among national supervisory bodies to ensure a consistent application of AML/CFT rules.
3. Adoption of the Sixth Anti-Money Laundering Directive (AMLD6)
The Sixth Anti-Money Laundering Directive (AMLD6), published with an effective date of July 10, 2027, requires member states, including Luxembourg, to transpose its provisions into national legislation within three years. AMLD6 will strengthen the existing AML/CFT framework by introducing more stringent measures and expanding the scope of predicate offenses related to money laundering.
AML 2025 changes implications for Investment Funds in Luxembourg
These regulatory changes will significantly impact the investment funds industry in Luxembourg:
- Enhanced Compliance Requirements: Investment funds must implement more robust AML/KYC procedures to align with the new regulations.
- Increased Oversight: With the establishment of AMLA, firms will face heightened scrutiny at both national and EU levels.
- Operational Adjustments: Firms may need to invest in new technologies and training to effectively meet the updated compliance standards.
Therefore, it is crucial for investment fund managers and associated entities in Luxembourg to stay informed about these developments and take proactive steps to ensure compliance with the forthcoming regulations.
Investment Minds Luxembourg: Your Partner in AML/KYC Compliance
Investment Minds Luxembourg is a leading consultancy firm specializing in the investment funds industry. With extensive experience in AML/KYC compliance and regulatory projects, we are well-equipped to assist your firm in navigating these changes. Our expert team provides tailored solutions to help you meet your compliance requirements efficiently and effectively. Contact us to learn how we can support your AML/KYC projects and ensure your firm’s success in the evolving regulatory landscape.
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