CSSF: Secure electronic transmission of documents

At the end of January 2019, the CSSF published a new circular (CSSF Circular 19/708) which extends the obligation to transmit documents by secure electronic means to the CSSF to the following entities:

• investment fund managers (e.g. alternative investment fund managers (AIFMs), management companies, …);
• SICARs (société d'investissement à risques) regulated by the Law of 15 June 2004 on SICARs;
• securitisation entities regulated by the Law of 22 March 2004 on securitisation; and
• pension funds regulated by the Law of 13 July 2005 on institutions for occupational retirement provision in the form of pension savings companies with variable capital (SEPCAVs) and pension savings associations (ASSEPs).

Circular 19/708 also details the procedures for the electronic transmission of documents to the CSSF and includes an Annex which lists the documents to be transmitted electronically.