Implementation of the 5th AML Directive into Luxembourg law: the last piece of the puzzle – Key aspects and changes of the law of 25 March 2020

The law1 of 25 March 2020 implementing EU Directive 2018/8432  (the “5th AML Directive”) and amending the law of 12 November 2004 on the fight against money laundering and terrorism financing, as amended (the “2004 Law”) entered into force on 30 March 2020 (the “New Law”).


This New Law is part of a legislative package, including the law of 25 March 2020 establishing a central electronic data retrieval system concerning IBAN accounts and safe-deposit boxes (the “Central Register Law”). Additional information on the Central Register Law may be found at the following link.

The aim of the New Law is to make the necessary adaptations to the 2004 Law in order to ensure the implementation of most parts of the 5th AML Directive (although certain aspects of the 5th AML Directive have already been implemented in the law relating to the register of beneficial owners – more information can be found at the following link). The New Law also to a certain extent goes further than the 5th AML Directive, by directly implementing certain of the recommendations of i.a. the Financial Action Task Force (“FATF”) which are not contained in the 5th AML Directive.

In the above context, the current newsflash aims at setting out the main changes brought by the New Law to the 2004 Law, and thus affecting all professionals subject to anti-money laundering and counter terrorism financing (“AML-CTF”) obligations (such as credit institutions, investment firms and other professionals of the financial sector, investment funds and their management companies, insurance companies, etc.). The main changes of the New Law are in essence the following:

  • New extended scope of professionals subject to AML-CTF obligations;
  • Reinforcement of the customer due diligence (“CDD”) measures applicable to professionals, including new rules for enhanced CDD (“EDD”) measures;
  • New rules relating to the recourse by professionals to third parties to carry out their CDD measures on their behalf (the so-called third party introducer regime);
  • Reinforcement of the powers of competent authorities and self-regulatory bodies in charge of the supervision of professionals subject to AML-CTF obligations; and
  • Strengthening of both national and international cooperation between competent authorities and self-regulatory bodies.


1. Bill of law °7467

2. EU Directive 2018/843 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing


Glenn Meyer


Banking & Financial Services

Stéphane Badey


Regulatory & Consulting

Manfred Hoffmann


Investment Management


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