Introduction
In March 2026, we published a client alert1 examining the Commission de Surveillance du Secteur Financier’s (CSSF) updated FAQ on crypto assets in investment funds and the key changes since the initial 2022 guidance. That alert highlighted, among other things, the new obligation on investment fund managers (IFMs) to assess their crypto-asset-related activities against article 60(5) of the EU Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114) (MiCAR), a provision that was set to increase in importance as the MiCAR transitional period drew to a close.
That moment has now arrived. The 18-month transitional period granted under article 143(3) of MiCAR to entities already providing crypto-asset…
