ONE consult brief #001

22 September 2021

Dear R-ONE Client,

In order to keep R-ONE up-to-date with all relevant regulatory developments, we have updated certain content in the system. Below, you will find a summary of the regulatory changes and how they have been captured in R-ONE. These updates are made as new regulations or Circulars go into effect, and we will keep you informed on a periodic basis.

>> Update I

10 June 2021
CSSF publishes a FAQ on the application of MiFID to Luxembourg IFMs:

FAQ concerning the Luxembourg Law of 17 December 2010 relating to undertakings for collective investment: section 10

FAQ concerning the Luxembourg Law of 12 July 2013 on alternative investment fund managers: section 26

> Impact Analysis

The FAQ clarifies under what circumstances and to what extent MiFID applies to IFMs, their third-party delegates and their investment advisers.

IFMs are expected to comply with the CSSF FAQ as soon as possible and by 31 December 2021 at the latest, considering the best interests of investors.


Monitoring Questionnaire ‘MiFID II – Prior Disclosure and Periodic Reporting’ has been updated to include these guidelines.


>> Update II

15 June 2021   
Regulation on cross-border distribution:

The new Commission implementing regulation on facilitating cross-border distribution of collective investment undertakings (CIUs) was published.

> Impact Analysis

The new implementing regulation deals with the forms, templates, procedures and technical arrangements for the publications and notifications of marketing rules, fees and charges, and specifies the information to be communicated for the creation and maintenance of the central database on cross-border marketing of AIFs and UCITS, as well as the forms, templates and procedures for the communication of such information.

It will enter into force on 5 July 2021 and apply in line with the new marketing rules as from 2 August this year (and regarding article 5 from 2 February 2022 respectively).


Monitoring Questionnaire ‘Cross-Border Marketing of Collective Investment Schemes’ has been created to include these guidelines.


>> Update III

18 June 2021
EDPB recommendations on data transfers under GDPR:

The European Data Protection Board (EDPB) published the final version of recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data.

> Impact Analysis

Data controllers relying on Standard Contractual Clauses (SCCs) are required to verify, on a case-by-case basis and, where appropriate, in collaboration with the recipient of the data in the third country, if the law of the third country ensures a level of protection of the personal data transferred that is essentially equivalent to that guaranteed in the European Economic Area (EEA).


Monitoring Questionnaire ‘GDPR – Data Protection, Privacy and Security’ has been updated to include these guidelines.


>> Update IV

Adequacy decisions on GDPR data exchange with UK:

The European Commission has adopted two adequacy decisions regarding data exchange between the EU and the United Kingdom: one under the General Data Protection Regulation (GDPR) and the other under the Law Enforcement Directive.

> Impact Analysis

The consequence of these decisions is that personal data can continue to flow freely from the EU to the UK as the Commission has deemed the personal data protection framework in the UK to be equivalent to GDPR.


Monitoring Questionnaire ‘GDPR – Data Protection, Privacy and Security’ has been updated to include these guidelines.



For further information, please contact:

Joana Cordeiro
tel: +352 621 512 447


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