Luxembourg - Fund management companies and AIFMs: Deadline for creation of cloud outsourcing register approaching

On 27 March 2019 the Commission de Surveillance du Secteur Financier (the “CSSF”) published CSSF Circular 19/714 (the “Circular”) amending CSSF Circular 17/654, in order to clarify the regulatory framework governing IT outsourcing relying on an external cloud computing infrastructure. Among other measures, the Circular introduced a new register to be maintained by CSSF supervised entities which includes all cloud computing outsourcings of material as well as non-material activities. Fund mana