On 23 August 2018, the CSSF issued Circular 18/698 addressed to
Luxembourg based Investment Fund Managers (UCITS Managers and AIFMs
including self-managed UCITS/AIF) setting out extensive
prescriptive guidance on their expectations regarding organization,
operations and substance, as well as the management information
systems and regulatory reporting to be in place to facilitate the
CSSF's ongoing supervision of these firms.
The new Circular is a useful compilation of guidance on the
required level of local substance and on how the core business
activities and internal controls functions should be organized,
including the conditions for delegation of activities as well as on
the concept of proportional application of the rules. The Circular
replaces Circular 12/546 that laid down the CSSF's expectations
for UCITS Managers, although in practice had also served as the
benchmark for AIFMs. The new Circular also contains important
guidance on what Investment Fund Managers
