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By Jens SCHMIDT, Partner, Wealth and Asset Management Consulting Leader Johann LOBO, Senior Manager, IT Regulation, Technology Risk, EY Luxembourg
On 9 April 2025, the CSSF published Circulars 25/881, 25/882, and 25/883, accompanied by a clarifying communiqué. These developments have drawn considerable attention across Luxembourg’s financial sector for their impact on information and communication technology (ICT) risk management, DORA implementation, and third-party oversight. Collectively, they represent a substantial step toward regulatory coherence and stronger digital resilience.
A central concern for leadership teams across investment funds and their managers, banks and payment service providers (PSPs) has been the scale and...
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