IT is key. This is not the slogan of an IT service provider but one of the lessons to be drawn from the CSSF Circular 18/698. Investment fund managers subject to this circular have strengthened obligations regarding their IT infrastructures, outsourcing, internal governance and data protection. One of the highlights in this context is the applicability of the so-called CSSF Cloud Circular 17/654 to investment fund managers, entailing an important compliance burden when relying on outsourced services that are based on a cloud infrastructure.
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