First CLO formed under new Luxembourg securitisation framework

April saw the incorporation of Ares European Direct Lending CLO 1 S.à r.l. in Luxembourg. This is noteworthy as it appears to be the first CLO vehicle established under Luxembourg's updated securitisation framework, following amendments to the Securitisation Law in 2022.​ Our research links Ares Management Corporation as collateral manager.

The impact of the 2022 reforms on domicile choices for European CLOs has been widely anticipated. The amendments introduced several key changes to the original 2004 law, including the permitting of active management which was expected to increase the appeal for CLOs in Luxembourg. However, until now all such incorporations have taken place in Ireland.

While Ireland remains the dominant domicile for European CLOs, owing to its established Section 110 regime and robust infrastructure, the incorporation of this Ares vehicle in Luxembourg marks a significant milestone. It indicates that leading managers are beginning to explore Luxembourg's revised legal framework for CLO structuring.​

At Atlantic Star Analytics, we specialise in providing detailed, jurisdiction-specific data on SPV formations, listings, and service provider engagements across multiple jurisdictions, including Ireland, Luxembourg, the UK, and Jersey.

Please feel free to contact us should you wish to discuss this development further or explore broader market trends.

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