Following the latest Brexit extension, the Luxembourg regulator, the Commission de Surveillance du Secteur Financier (the “CSSF”), has issued a further communiqué to confirm the new deadline for UK firms that wish to benefit from a 12 month transitional period. The new date is 15 January 2020.

UK MiFID firms and UK fund managers providing their services under the passport and wishing to benefit from a 12 month transitional regime in the event of a hard Brexit will need to take action. As we have reported before, a mandatory notification is also required from UK managers of alternative investment funds (AIFs) established in Luxembourg wishing to remain as a third-country manager of those AIFs after a hard Brexit.

A notification is not required for UK MiFID firms providing portfolio management services in Luxembourg under a delegation arrangement provided for under Article 20 (1) of the AIFMD.

These announcements have no impact on other non-EU managers (such as US managers) managing Luxembourg structures.