The CSSF’s Circular of August 23 in Luxembourg is ostensibly all about combating money laundering and terrorist financing. But it covers pretty much every aspect of how a fund management company in Luxembourg should operate, formalising many practices.
The law firm Allen & Overy has covered what is included in this Circular. Allen & Overy’s coverage  goes on for 140 pages. There is a huge amount of detail in it. Implementation and compliance with the Circular looks like it will add significantly to costs.