Impact of Brexit on Luxembourg life insurance companies
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On 8 April 2020 the Luxembourg Commissariat aux Assurances (the CAA) published a new information note (the Information Note) highlighting the impact of Brexit on the Luxembourg insurance sector1, this time on the application of CAA circular letter 15/3 on investment rules for life insurance products linked to investments funds (the Circular 15/3).
As from 1 January 2021, investments into external funds domiciled in the UK or its dependent territories as well as financial instruments issued by issuers located in the UK or its dependent territories will need to take into account the rules applicable to the new classification of these countries pursuant to Circular 15/3. In particular, certain types of funds may be subject to lowered investment thresholds, while others may be required to adapt their investment policies.
The Information Note provides guidance on the impact of Brexit on investments of unit-linked life insurance products in external funds as well as internal collective, dedicated or specialized funds.