Topic

Digital & Virtual Assets

Crypto-assets, tokenization and virtual assets as they meet regulated fund structures. Articles here follow the CSSF's approach to funds investing in virtual assets, from its earlier FAQ distinguishing UCITS from AIFs to the 2026 update on crypto exposure in UCITS, together with how indirect exposure can amount to full exposure without a crypto licence, ESMA's opinion on broker models under MiCA, and why tokenization of fund shares is promising but not yet practical under current rules.

Illustration of a tokenised investment fund using distributed ledger technology to simplify the traditional transfer agent model.

Tokenized Funds: Could the Transfer Agent role be reduced?

Luxembourg’s new CSSF FAQ shows that the main limit to a fully tokenized fund may no longer be technology, but regulation.

6 October 2026 By Diego Ofano

Digital & Virtual Assets

Crypto exposure without a Crypto license: when indirect exposure becomes full exposure

A Luxembourg AIF can be fully exposed to crypto-assets. The AIFM, managing the fund, does NOT need to obtain a crypto-specific license. Not because of a compliance lack, but because of how the framework is currently designed. When approaching Crypto exposure in investment funds, the CSSF has drawn a clear line between direct and indirect exposure. In practice, that line might be more theoretical than real.

7 April 2026 By Diego Ofano

Digital & Virtual Assets

Crypto and UCITS: what has really changed? Very little

On February 4th 2026, the CSSF has published a new FAQ related to the exposure of Crypto-Assets in the UCITS funds. This change in orientation of the CSSF has been taken with enthusiasm by many players. The message that many understood was very simple: crypto on the UCITS funds is now allowed. From now on, UCITS investors will be exposed to crypto-assets. The reality is far from it.

1 April 2026 By Diego Ofano

Digital & Virtual Assets

Tokenization in the Fund Industry: why it is the future but not yet the present, and a possible solution

Tokenization of shares has the potential to bring significant innovation to Luxembourg's financial services sector and surely worldwide, offering opportunities to improve processes and operational efficiency in the Investment fund Sector. But today, is tokenization truly beneficial for an investment funds in Luxembourg? The answer is most probably NO - at least not within the current regulatory framework.

17 December 2024 By Diego Ofano

Digital & Virtual Assets

ESMA's Opinion on Broker Models Under MiCA: Impact for Crypto-Asset Service Providers

1 August 2024 By Diego Ofano

Digital & Virtual Assets

Between Innovation and Protection: CSSF's Approach to Digital Asset Investments

The Luxembourg Commission de Surveillance du Secteur Financier (CSSF) has released an update on the FAQ Virtual Assets – Undertakings for collective investment in relation to the UCIs investing directly or indirectly in virtual assets and has once again demonstrated its commitment to maintain a balanced and progressive regulatory environment. With its latest guidelines, the CSSF has drawn a clear line between the investment capabilities of Undertakings for Collective Investment in Transferable Securities (UCITS) and Alternative Investment Funds.

7 March 2024 By Diego Ofano