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ARTICLE · 30 OCTOBER 2024

CSSF Clarifies Its Expectations On How Delegated Activities Must Be Monitored By Investment Fund Managers

Arendt & Medernach
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While the CSSF approves of the overall level of compliance with the UCITS and AIFMD framework with regard to the delegation of the portfolio management function, it has nonetheless issued several recommendations.

LuxembourgFinance and Banking
Adrian Aldinger
Adrian Aldinger
Pierre Beissel
Pierre Beissel
Sébastien Binard
Sébastien Binard
Camille Bourke
Camille Bourke
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While the CSSF approves of the overall level of compliance with the UCITS and AIFMD framework with regard to the delegation of the portfolio management function, it has nonetheless issued several recommendations to further strengthen adherence to the relevant legal and regulatory requirements. Luxembourg IFMs must assess how they monitor the delegation of the portfolio management function by the end of March 2025, at the latest.

On 23 October 2024, the CSSF published a report with its observations made during a supervisory thematic review on the monitoring processes put in place by investment fund managers (IFMs) who delegate the portfolio management function. The aim of the CSSF's thematic review was to assess the compliance of Luxembourg-based IFMs with the relevant provisions of the UCITS and AIFMD framework regarding the supervision of such delegation and related contingency planning. For this review, they selected a sample of IFMs managing regulated investment

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