AIFs having a professional depositary of assets other than
financial instruments appointed as their single depositary and
having designated an electronic money institution or a payment
institution to hold their cash accounts have until 30 June 2023 to
regularise their situation by appointing an eligible entity for the
holding of such cash accounts (i.e. a central bank, a credit
institution authorised per Directive 2000/12/EC or a third country
authorised bank.)
On 18 October 2022, the CSSF published a clarification regarding
the eligible entities for opening cash accounts concerning
alternative investment funds
("AIF").
The CSSF states that, based on its observations, some AIFs,
particularly those having appointed as their single depositary a
professional depositary of assets other than financial instruments
(the "PDAOFI"), as defined in article
26-1 of the Law of 5 April 1993 on the financial sector, as
amended, use or intend to use for the purpose of holding
