Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 06 MARCH 2026

CBI Issues "Dear CEO” Letter - Outsourcing Risk In Fund Administrators And Depositaries

Dillon Eustace
Dillon Eustace
Contributor
Dillon Eustace

Dillon Eustace

Dillon Eustace is one of Ireland’s leading law firms focusing on asset management and investment...

View firm profile
Explore more from Dillon Eustace

On 6 March 2026, the Central Bank of Ireland (CBI) issued a letter (Dear CEO Letter) on its findings arising from the thematic inspection of outsourcing risk which it conducted on Fund Administrators...

IrelandFinance and Banking
Karen Jennings
Karen Jennings
Author LinkedIn connections

On 6 March 2026, the Central Bank of Ireland (CBI) issued a letter (Dear CEO Letter) on its findings arising from the thematic inspection of outsourcing risk which it conducted on Fund Administrators and Depositaries, collectively known as Fund Service Providers (FSPs), in 2025 (Thematic Inspection). 

The Dear CEO Letter outlines that the Thematic Inspection sought to assess the outsourcing oversight frameworks established by FSPs taking into consideration the good practices for the effective management of outsourcing risk as outlined in the CBI’s Cross Industry Guidance on Outsourcing published in December 2021. For Fund Administrators, the Thematic Inspection also considered the outsourcing requirements set out in the Investment Firms Regulations 20231 and related Central Bank guidance.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

CBI Consults On Third-Party Risk

The Central Bank of Ireland has published a consultation paper proposing new guidance on managing third-party risks that extends beyond traditional outsourcing to encompass partnerships, joint ventures, and fintech collaborations. The proposed framework aligns with recent European Banking Authority guidelines and DORA, introducing a lifecycle-based approach with enhanced contractual provisions and broader scope than the 2021 guidance it will replace. Financial entities now face the challenge of identifying
IrelandFinance and Banking
William Fry LLP
William Fry LLP
Article

Final EBA Guidelines On The Sound Management Of Third-party Risk: What Financial Entities Need To Know

The European Banking Authority has published final Guidelines on the sound management of third-party risk regarding non-ICT services, replacing the 2019 Outsourcing Guidelines and introducing a broader regulatory framework. Financial entities will need to navigate expanded scope requirements, enhanced governance standards, and alignment with DORA while managing compliance timelines and contractual obligations.
IrelandFinance and Banking
Arthur Cox
Arthur Cox
Article

Alternative Investment Funds

Ireland offers a sophisticated regulatory framework for Alternative Investment Funds, with structures ranging from ICAVs and Investment Limited Partnerships to Unit Trusts and Common Contractual Funds. The jurisdiction provides flexible options for both retail and institutional investors, with distinct regulatory pathways for RIAIFs, QIAIFs, and ELTIFs, each designed to accommodate different investment strategies and liquidity profiles while maintaining robust investor protections.
IrelandFinance and Banking
K&L Gates
K&L Gates
Article

SFDR 2.0 Trialogue Negotiations: Key Areas Of Focus For Fund Managers

The European Commission's proposed overhaul of the SFDR regime is entering crucial trialogue negotiations, with the Irish Presidency aiming to reach agreement by year-end. While the Council and Parliament have aligned on key issues like professional investor opt-outs, significant divergences remain on exclusion criteria for Transition funds, PAI reporting requirements, and engagement strategy disclosures that will shape the future of sustainable finance regulation.
European UnionFinance and Banking
Dillon Eustace
Dillon Eustace
Article

Irish Budget 2027: Key Tax Measures For The Financial Services Industry

Ireland's Budget 2027 introduces a lower exit tax rate for fund investors, clearer rules for Irish ETFs, and a new Retail Investment Account, while leaving the controversial eight-year deemed disposal rule unchanged. The package also includes Pillar Two updates, interest relief reforms, and a capital gains tax reduction, offering targeted refinements for the financial services sector rather than the fundamental reform many had anticipated.
IrelandTax
Dillon Eustace
Dillon Eustace
Article

CIMA’S New AML Audit Rules Effective 18 September 2026 And What Investment Funds Need To Know

The Cayman Islands Monetary Authority has introduced sweeping changes to anti-money laundering audit requirements for investment funds, mandating independent audits of entire compliance programmes by September 2026. This marks a fundamental departure from previous practice where internal AML officers could conduct their own testing, raising critical questions about implementation timelines, qualified auditor availability, and compliance costs for funds operating in the jurisdiction.
Cayman IslandsWealth Management
Dillon Eustace
Dillon Eustace
Article

AMLD6 And Beneficial Ownership Central Registers: New Access Rules In Ireland

Ireland has introduced significant amendments to its beneficial ownership registers in 2026, implementing the Sixth Anti-Money Laundering Directive (AMLD6) framework. These reforms fundamentally restructure access rights to the Central Register of Beneficial Ownership of Trusts and Corporate Entities, moving away from unrestricted public access toward a tiered system that balances transparency with privacy rights while maintaining accessibility for legitimate anti-money laundering purposes.
IrelandCorporate/Commercial Law
Dillon Eustace
Dillon Eustace
Article

SFDR 2.0 Trialogue Negotiations: Key Areas Of Focus For Fund Managers

The European Commission's proposed overhaul of the SFDR regime is entering crucial trialogue negotiations, with the Irish Presidency aiming to reach agreement by year-end. While the Council and Parliament have aligned on key issues like professional investor opt-outs, significant divergences remain on exclusion criteria for Transition funds, PAI reporting requirements, and engagement strategy disclosures that will shape the future of sustainable finance regulation.
European UnionFinance and Banking
Dillon Eustace
Dillon Eustace