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On 25 February 2019, the European Banking Authority ("EBA") released its revised Guidelines on outsourcing arrangements ("(EBA) Guidelines"). Such Guidelines revise and replace both the current guidelines on outsourcing arrangements which date back to 2006 and the EBA guidelines for the use of cloud service providers by financial institutions dating back to 2017. Contrary to such previous guidelines, the new EBA Guidelines have a very broad scope of application and apply to credit institutions, investment firms subject to the Capital Requirement Directive(1) and payment and electronic money institutions (together "Institutions"). Furthermore, the new EBA Guidelines mean an important increase in requirements compared to both the current EBA guidelines and the Luxembourg financial sector...
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