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By Norman FINSTER, Partner, Alternative Investments Johann LOBO, Senior Manager, Governance, Risk Compliance, EY Luxembourg
In recent years, financial institutions have increasingly relied on third-party providers for key operational and support functions. The EBA’s draft Guidelines on non-ICT third-party risk management clarify that these arrangements pose material prudential and governance risks and introduce a harmonized supervisory framework which, for Luxembourg institutions, aligns as far as possible with DORA while limiting additional supervisory burden.
From outsourcing to structural dependency
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