K&L Gates·FINANCIAL REGULATION

Luxembourg CSSF Publishes First FAQ on Fund Tokenisation

The CSSF has issued its initial FAQ, outlining how Luxembourg UCIs can issue tokenised units while meeting regulatory and AML obligations.

The Commission de Surveillance du Secteur Financier (CSSF) released the first version of a FAQ on tokenisation of investment funds, clarifying how Luxembourg undertakings for collective investment (UCIs) may issue native tokenised shares on distributed ledgers while complying with existing legal frameworks, anti‑money laundering (AML) requirements, and the Dematerialised Securities Law. The document highlights that tokenised units can be registered or dematerialised and stresses a technology‑neutral stance. It also details notification timelines for control‑agent activities, including ICT outsourcing, and emphasizes conformity with the Digital Operational Resilience Act (DORA) for critical functions. Firms with tokens now or planning to tokenise should review their UCI or IFM structures, confirm registrar obligations, assess DORA compliance, and engage early with CSSF’s Innovation Hub. The FAQ is subject to updates; entities should monitor the CSSF site for changes.

luxembourgfund-tokenisationcssfdoraucisdltanti-money-laundering
Read the original firm alert → Tuesday, October 13, 2026

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