In November 2018 the Federal Financial Supervisory Authority (“Bundesanstalt für Finanzdienstleistungsaufsicht”, “BaFin”) and Deutsche Bundesbank published a guidance on outsourcing of services to cloud service providers (“Guidance on Cloud Services”). According to BaFin and Deutsche Bundesbank the Guidance on Cloud Services has not stipulated any new requirements, but has condensed the

The German Federal Financial Supervisory Authority (“BaFin”) recently published an article that provides guidance on the regulatory framework for cloud computing.  This is a follow-up to the circular letter Minimum Requirements for Risk Management (“MaRisk”), which was published in German in October 2017 and the circular letter Supervisory Requirements for IT in Financial Institutions (“BAIT”),