CSSF On Mandatory Notifications In A No-Deal Brexit Context

Following the publication of Luxembourg laws of 8 April 2019¹ (see our previous briefing here), the Luxembourg Financial Sector Supervisory Authority (CSSF) has issued two press releases aimed at undertakings for collective investment (UCIs) and/or their managers, and certain firms currently authorised in the United Kingdom (UK) which intend to continue their activities in Luxembourg following a withdrawal of the UK from the European Union (EU) without the conclusion of a withdrawal agreement (no-deal Brexit). UCIs and/or their managers established in the UK that are currently authorised entities under the UCITS Directive² and/or the AIFM³ Directive respectively, as well as firms currently authorised in the UK under the provisions of MiFID II, CRD, PSD 2 or EMD⁴ will, from the date the UK leaves the EU, be considered as "third-country firms/entities". This means they shall no longer benefit from the relevant passporting regime and, as a result, will not be able provide