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Regulatory update

AMLR 2027: what changes for Luxembourg funds, ManCos and PFS

The EU AML Regulation applies from 10 July 2027. What changes in your policy, BWRA, CDD and record keeping, and what Luxembourg funds, ManCos and PFS can update now.

The EU Anti-Money Laundering Regulation applies from 10 July 2027 and replaces most of the national rules your AML/CFT policy currently cites. Here is what moves, document by document, and what you can update today without waiting for the CSSF to amend Regulation 12-02.

Application date and scope

Regulation (EU) 2024/1624 applies directly in all Member States from 10 July 2027. Unlike the directives it replaces, it does not need transposition into the Law of 12 November 2004, which means your policy will have to cite the Regulation itself alongside the Luxembourg provisions that remain (supervisory powers, sanctions, the CRF's role).

Obliged entities in scope include all CSSF and AED supervised professionals: credit institutions, investment firms, PFS, AIFMs and UCITS management companies, and investment funds themselves where they are not managed by an authorised manager. RAIFs and unregulated SCSps keep their AED supervision for AML purposes.

What changes in the policy

  • Legal framework section: add the AMLR and the AMLA technical standards as primary sources; keep the 2004 Law for national specificities.
  • Governance: the compliance manager and compliance officer functions map onto the Luxembourg RR and RC, but their minimum tasks are now listed in the Regulation. The RR/RC section of the policy should reproduce them.
  • Group-wide policies become mandatory for parent undertakings, with a defined content list.

What changes in the BWRA

The AMLA guidelines on business-wide risk assessment set a minimum methodology: risk factors by category, inherent and residual scoring, documented weighting and a board-approved conclusion. Most Luxembourg BWRAs already follow this shape after CSSF Regulation 12-02, art. 4; the change is in the evidence expected behind each score.

CDD and UBO thresholds

The beneficial ownership threshold stays at 25% but the Regulation adds a lower threshold regime for higher-risk sectors and a detailed definition of control through other means. Your CDD procedure should already separate ownership from control; if it does not, this is the first thing to change.

Record keeping

Retention remains five years after the end of the business relationship or occasional transaction, with deletion required at the end of that period unless another law applies. The Record of Steps template already contains the retention and deletion log; check that your data-protection retention schedule says the same thing.

What to update now

  • Add an "AMLR readiness" line to your 2026 compliance monitoring plan with a Q1 2027 policy revision.
  • Refresh the BWRA in early 2027 using the AMLA methodology so the July version is not the first attempt.
  • Rewrite the legal framework chapter in the policy now, with the AMLR references marked as "applicable from 10 July 2027".

This article is general information for compliance practitioners. It is not legal advice.

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