On 23 August 2018, the CSSF issued its circular 18/698 on the substance requirements (the "CSSF Circular") applying to Luxembourg management companies. The management companies to which the CSSF Circular applies, include alternative investment fund managers ("AIFM"), as well as management companies subject to chapters 15 ("UCITS ManCo"), 16 and 17 of the Law of 17 December 2010 ("UCITS Law") relating to undertakings for collective investment.
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Source: JurisNews – Investment Management, 2018
The views expressed in this article reflect some of the author's experience to date on the subject matter. As the Luxembourg fund market continues to develop - namely in relation to Luxembourg ManCos providing MiFID II portfolio management services - these views may and will most likely continue to evolve in one way or another. This article should not be construed as legal advice rendered by the author or by NautaDutilh Avocats Luxembourg S.à r.l., nor should it be interpreted as reflecting the views of NautaDutilh Avocats Luxembourg S. à r.l.