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ARTICLE · 14 JANUARY 2026

CSSF Circular 25/901 – Key Changes For SIFs And, Indirectly, RAIFs

Maples Group
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On 19 December 2025, the Commission de Surveillance du Secteur Financier (CSSF) published Circular 25/9011 ("Circular 25/901"), which consolidates and modernises the regulatory framework applicable...

Cayman IslandsFinance and Banking
Johan Terblanche
Johan Terblanche
Donnchadh McCarthy
Donnchadh McCarthy
Michelle Barry
Michelle Barry
Antonios Nezeritis
Antonios Nezeritis
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On 19 December 2025, the Commission de Surveillance du Secteur Financier (CSSF) published Circular 25/90111 ("Circular 25/901"), which consolidates and modernises the regulatory framework applicable to specialised investment funds ("SIFs"), investment companies in risk capital ("SICARs"), and part II undertakings for collective investment ("Part II UCIs"). Circular 25/901 repeals several older circulars (including CSSF circular 02/80 which applied to Part II UCIs, 07/309 which applied to SIFs, 06/241 which applied to SICARs) and introduces clarifications aimed at simplification and consistency.

This legal update focuses exclusively on the impact of Circular 25/901 on SIFs and on SIF-like reserved alternative investment funds ("RAIFs").

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