Notes from the desk.
Short, positioned commentary on questions clients are actually facing. Each note distinguishes black-letter law, regulator practice, and market practice — stated separately, because they are not the same thing.
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After the MiCA transition: remediation, not preparation
The CASP transitional period ended on 1 July 2026. Firms that did not obtain authorisation are past the planning stage: the live questions are what to stop, what to restructure toward the financial-instruments perimeter, and how to sequence client migration while doing so.
2026-07-23
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Substance in Luxembourg securitisation structures: what the 2004 Law does not say
The 2004 Securitisation Law is largely silent on operational substance. The expectations that decide outcomes come from tax law, regulator practice, and the market's own conventions — three sources that do not always agree, and are rarely read together.
2026-07-23
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CBAM's definitive regime: liabilities are accruing now
The definitive regime has applied since 1 January 2026. The first certificate purchases and surrenders arrive from February 2027, but the liability attaches to imports made this year — and the post-Omnibus 50-tonne threshold means borderline importers should be quantifying exposure, not assuming exemption.
2026-07-23
Discuss a note
If one of these lands on your desk as a live question, write to us. Notes are general commentary. Applying them to a specific structure or business is the engagement — and a short call generally clarifies scope and feasibility.
