Given the postponement of Brexit1, the CSSF has indicated in its Press Release (19/54) that its previous communications regarding notification obligations for UK financial sector companies wishing to continue to provide services in Luxembourg in case of a Hard Brexit under the transitional regime resulting from the Brexit laws (see our Newsletter - May 2019) must now be read as taking 31 January 2020 as the reference date for a potential Hard Brexit2.

As the CSSF has set out notably in Press Release (19/33) and in Press Release (19/43), in order to benefit from the grandfathering regime for existing contractual arrangements in the banking, investment services and payment services sector, relevant UK entities must introduce a Brexit notification via the dedicated eDesk portal on its website. Press Release 19/54 again encourages UK entities who have not yet done so to submit this notification at their earliest convenience.

It must also be recalled that the continuation of activities by UK firms through the conclusion of new contracts following a Hard Brexit requires to submit an application for an authorisation to the CSSF. 

Footnotes

1. See the article " Brexit Postponed" in the EU law, competition and antitrust section of this Newsletter.

2. See also the article " Brexit: New deadlines for CSSF notifications" in the Asset management and investment funds section of this Newsletter.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.