Luxembourg AML: AED Circular 792 quater on Client Identification

Luxembourg's anti-money laundering framework is shared between several supervisors. The Administration de l'enregistrement, des domaines et de la TVA (AED) supervises a number of professionals under the AML Law of 12 November 2004, as amended. In January 2026 it published a new circular on client identification and a newsletter on reporting by alternative investment funds. This guide summarises both, based on a briefing from the law firm Elvinger Hoss Prussen posted on 9 February 2026. The briefing does not say which categories of professional are covered, so check the AML Law or the AED website to confirm whether your activities fall within the AED's supervision.

What the AED published

1. AED Circular 792 quater of 26 January 2026. It replaces Circular 792 ter of 28 July 2025 and applies to all AED-supervised professionals.
2. An AED newsletter for alternative investment funds (AIFs) and reserved alternative investment funds (RAIFs), dated January 2026, on reporting obligations.

Key points of Circular 792 quater

• Identification versus verification. The circular maintains the distinction between identifying a customer and verifying their identity. Its scope now covers legal entity and legal arrangement customers, not only natural persons.
• Reliable sources. Professionals must identify and verify clients using reliable, independent sources and risk-based measures.
• Foreign identity documents. For non-Luxembourg identity documents of individuals, the original must be in a language the professional can understand. The AED may request a translation into Luxembourg's official language or English, which must be provided within two weeks.
• Legal entities. The requirements for legal entity customers are largely aligned with those imposed by the Commission de Surveillance du Secteur Financier (CSSF), the financial sector regulator.
• Authentication by an authority. Authentication by a competent, independent authority is distinct from general verification. Professionals may use it as an identity verification method in enhanced due diligence.

The RAIF and AIF newsletter

The newsletter explains that all RAIFs must file the AML/CFT questionnaire and the RC report covering 2025. Other non-regulated AIFs must prepare the RC report but file it only if the AED requests it, and they should ensure that their domiciliary agent forwards any AED correspondence promptly. The AED has warned that late filing will face enforcement. RAIFs should check the AED website regularly for updates on deadlines and filing instructions.

Why the identification detail matters

The difference between identification and verification is often blurred in practice. Identification means gathering who the customer says they are, while verification means confirming that against reliable independent evidence. Extending the circular to legal entities and arrangements is a reminder that corporate customers need the same two-step discipline as individuals, with a particular focus on who ultimately owns and controls them. Our guides to ultimate beneficial ownership and KYC and customer due diligence for accountancy practices cover those basics, although the Luxembourg rules differ in detail.

National context

Luxembourg published a national risk assessment of money laundering in 2025, which supervisors use alongside the Law and circulars. Professionals should read the sections that relate to their own sector when updating their business risk assessment.

Putting identification and verification into practice

The following example is our illustration, not text from the circular. Suppose a company asks you to act for it. At the identification stage you record its name, legal form, registered office and the people who own and control it. At the verification stage you check those details against reliable, independent sources, such as an official register or a certified document, and you do the same for the individuals behind it. If one of those individuals presents a foreign passport in a language you cannot read, the circular says the AED may ask for a translation, so it is sensible to have a translator or a process in place before the request arrives.

Common pitfalls

• Treating a single document as proof. Verification should rely on reliable, independent sources and be proportionate to risk.
• Forgetting legal arrangements. The circular now covers legal arrangements as well as companies, so trusts and similar structures need the same discipline.
• Missing the funds deadline. Fund clients need their AML/CFT filings made on time, and late filing will face enforcement, according to the AED newsletter.
• Poor records. Without a note of what you checked and why, a good process is hard to prove.

A practical checklist

1. Confirm your supervisor. Work out whether the AED, the CSSF or another authority supervises you.
2. Review your onboarding forms. Make sure they separate identification from verification, and cover legal entities and arrangements.
3. Prepare for translation requests. If you accept foreign identity documents, have a process for obtaining a translation within two weeks.
4. Check fund reporting. If you act for RAIFs, confirm that the AML/CFT questionnaire and the RC report for 2025 have been filed.
5. Keep evidence. Record the sources you used and why you considered them reliable and independent.

Frequently asked questions

What does Circular 792 quater replace?

Circular 792 ter of 28 July 2025.

Who must follow the circular?

All professionals supervised by the AED under the AML Law. The briefing we used does not list the categories, so check the Law.

What must RAIFs file?

The AML/CFT questionnaire and the RC report covering 2025.

How long is the translation deadline?

Two weeks, if the AED asks for a translation of a foreign identity document into Luxembourg's official language or English.

Next steps

Read Circular 792 quater on the AED website and compare it with your onboarding procedures. This article is general information and not legal advice. To develop your AML skills further, explore Learnsignal's CPD courses.