New requirements for fiduciary arrangements: setting up by their fiduciary agent of an internal file on their beneficial owners

On 21^st August 2018, the law on the information to be obtained and held by fiduciary agents (the “2018 Law”) implementing part of Article 31 of EU Directive 2015/849 of 20^th May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (the “4^th AML Directive”) was published in the Luxembourg Gazette N° 702 on 21^st August 2018. The 2018 Law had been adopted by Parliament on 26^th July 2018 and will enter into force on 25^th August 2018.

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