By Laure Mersch, Marc Meyers, Max Welbes, Thibaut Partsch

The CSSF issued on 23 August 2018 a new circular 18/698 regarding the authorisation and organisation of Luxembourg investment fund managers (the Circular). This Circular entered into force with immediate effect and replaced and superseded the CSSF circular 12/546. The Circular sets out 3 types of requirements:

  • those previously formalized in CSSF circular 12/546;
  • those already applied by the CSSF, but not codified as yet; and
  • new requirements.

As a result, existing investment fund managers as well as entities currently applying or intending to apply for a licence as an investment fund manager may have to review their organisation in order to comply with the requirements under the Circular.