On 6 November, the CSSF released a new press release 19/54 which is intended to replace the reference date to a hard Brexit (i.e. 31 October 2019) in all previous CSSF communications with the new Brexit date, 31 January 2020.
In particular, the CSSF reminds UK firms, UCIs and/or their managers who intend to continue to provide services in Luxembourg after a hard Brexit that they may still apply to benefit from the transitional period. UK firms can notify the CSSF through the dedicated
e-desk portal ‘at their earliest convenience’ but UCIs and their managers must do so no later than 15 January 2020. Similarly, UK AIFMs managing Luxembourg AIFs may continue to manage Luxembourg AIFs – whether regulated or not – after a hard Brexit as a ‘third country manager’ without the benefit of a transitional period, subject to the conditions set forth in the CSSF press release
19/48 and by providing the relevant documents and confirmations by
e-mail to the CSSF before 15 January 2020.
Finally, the CSSF reminds the impacted entities that they should take all necessary steps to prepare and anticipate a hard Brexit, and inform investors and customers.
