CSSF updates its FAQ on virtual assets

On 6 April 2023, the Luxembourg Commission de surveillance du secteur financier (the CSSF) updated its FAQ on Virtual Assets for UCIs.

11 April 2023

Publication

The CSSF clarified that a Luxembourg IFM does not need to be licensed to manage virtual assets in case its AIFs only indirectly invest in virtual assets through one or more target funds. If however an AIF invests more than 20% of its NAV in such target funds, the AIFM needs to be licensed for the “fund of funds” strategy.

An IFM is responsible for determining whether a target fund has virtual assets as main exposure. It is then the responsibility of the IFM to assess the ability of the target fund’s manager to identify and manage the risks of the virtual asset investments.

For further information, please don’t hesitate to reach out to our Luxembourg asset management & investment funds team.

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