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By Jérémie SCHAEFFER and Olivier de La GUERONNIERE, ATOZ Tax Advisers*
On 27 March 2019, the CSSF issued a new Circular 19/714 (the "Circular") in order to update its guidelines on the use of cloud computing infrastructure.
In the introduction to the Circular, the CSSF clearly explains that the purpose of the update is notably to "take into account the experience gained by the CSSF and the supervised entities" since the application of the CSSF's initial "Cloud Circular" 17/654 which clarified to what extent cloud computing infrastructure could be outsourced.
The CSSF also acknowledges that although the requirements of the European Banking Authority ("ECB")...
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