Luxembourg Cloud computing rules for investment fund managers: a reminder of the obligations 6 months before their Cloud Register must be drawn up

Last year, investment fund managers (IFMs) were caught by surprise with the immediate application of Circular 17/654 on IT outsourcing relying on a cloud computing infrastructure (the Cloud Circular), but every cloud has a silver lining. Circular 19/714, which amends the Cloud Circular, significantly reduces and clarifies the obligations of IFMs.

This article aims at providing a reminder to IFMs of the rules applicable to them in relation to their cloud computing solutions exactly 6 months before the end of the grace period to establish their cloud outsourcing register (due by 27 March 2019).

Please see full article below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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