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ARTICLE · 16 APRIL 2019

Circular CSSF 19/714: Application Of The Cloud Circular To Investment Fund Managers

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On 27 March 2019, the CSSF issued a new Circular 19/714 (the "Circular") in order to update its guidelines on the use of cloud computing infrastructure, as presented in its initial circular 17/654.

LuxembourgFinance and Banking
Jérémie Schaeffer
Jérémie Schaeffer
Olivier De La Guéronnière
Olivier De La Guéronnière

On 27 March 2019, the CSSF issued a new Circular 19/714 (the " Circular ") in order to update its guidelines on the use of  cloud computing infrastructure, as presented in its initial circular (the " Cloud Circular ") 17/654.

Inclusion of investment fund managers

The Circular now explicitly provides that all investment fund managers subject to Circular CSSF 18/698 on the  authorization and organization of investment fund managers incorporated under Luxembourg law must comply with the  requirements of the Cloud Circular .

Related obligations

The obligations that investment  fund managers must now comply with are not new, insofar as they are a mere extension  of the obligations already applicable to credit institutions, professionals of the financial sector as well as payment  institutions and electronic money institutions.

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