Outsourcing duties and CAA CL 21/15 and 22/16

The two Circular letters 21/15 and 22/16 of the CAA establish the framework applicable to insurance and reinsurance companies when outsourcing activities and functions to third-party service providers or other entities within the same group.

It introduces new requirements, in particular as regards to the selection, documentation, and communication to the CAA of Cloud computing solutions (CAA 21/15), Business processes and IT outsourcing arrangements (CAA 22/16).

To be compliant, insurance and reinsurance companies must review their internal governance processes by allocating sufficient resources to document and oversee their outsourcing relationships with such service providers.

This training session aims focuses on the requirements introduced by both circular letters, especially in terms of outsourcing assessment, due diligence, risk assessments, insurance secrecy, notifications, oversight of service providers, and exit strategies. Our experts will also share their experience of best identified market practices and essential steps towards ensuring outsourced activities comply with the regulatory requirements.

By the end of the training, participants will be able to:

• explain what outsourcing means, and what steps the organisation will need to take to comply with these regulatory requirements;
• assess whether a service provided by a third party may qualify as outsourcing or not and which Circular Letter will govern the outsourcing relationship;
• apprehend the overall impact of the key requirements on their organisation;
• understand the key documentation requirements and impacts of the outsourcing framework.

• Regulatory landscape
• Outsourcing categorisation and criticality assessment
• Outsourcing lifecycle
• Documenting outsourcing
• Notification to the CAA
• Three lines of defence model
• Main roles as defined in the Circular Letters

This training is coordinated by Anthony Dault, Partner at PwC Luxembourg. It will be delivered by experts from PwC Luxembourg's Insurance sector, who have acquired in their daily work a significant and detailed experience of the issues faced by insurance market players. (Depending on the needs expressed, PwC Luxembourg may mobilise experts within its network).

Anthony is a partner specialised in insurance/reinsurance and international tax structure, and is actively involved in PwC Luxembourg Reinsurance and Insurance Group (RIG), including the insurance and reinsurance regulatory team. Anthony has more than 18 years of experience serving several multinationals, subsidiaries of European and US registered companies reporting under IFRS or Lux GAAP in the insurance and reinsurance sector, starting in 2003 in PwC Paris insurance department and in PwC Luxembourg. In the past years, Anthony has been involved in the development of the PwC Luxembourg insurance regulatory practice, with a strong focus on cross-border distribution as well as regulatory licencing projects. In that context, he co-heads the IDD service offering of PwC Luxembourg, and is a member of the ACA IDD working group.