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Jean-Noël Lequeue (jnl): Boards of Directors adapt to Compliance

Jean-Noël Lequeue, Managing Director, of the internal control consulting firm jnl discusses developments and deciphers the importance of compliance within boards of directors. Interview.

What changes are facing compliance officers?


After several consecutive years of significant regulatory tightening, Claude Marx, Director General of the CSSF, has announced a stabilization. Despite this, Anti-Money Laundering (AML) procedures, as well as the fight against money laundering and terrorist financing, will remain a heavy burden for Compliance Officers (CO). Like the CSSF and the Ministry of Finance, we remain attentive to the arrival of the Financial Action Task Force (FATF) in Luxembourg. A strengthening of AML regulation seems to be on the agenda. Another new feature is that COs must now comply with the rules laid down in the General Data Protection Regulations (GDPR) on the use of personal data. These tasks are all the more complex because of the poor consultation between the various national and European institutions responsible for the measures.

“We remain attentive to the arrival of the Financial Action Task Force (FATF) to Luxembourg. A strengthening of AML regulation seems to be on the agenda.”

How does compliance impact boards of directors?

As boards of directors have more responsibilities, they develop a close relationship with compliance. In this respect, CSSF circulars 12/552 and 18/698 clarify their role in this area. However, this should be pushed further as there are few regulations clearly defining the level of training and obligations of ManCo administrators on the AML issue. Few members of boards of directors are aware that CSSF sanctions against companies apply for life, and should must be mentioned in administrators’ declarations on honour. It remains important to better clarify the role of the board so that it can effectively control the executive committee.

What milestones did jnl mark in 2019?

The sale of part of the jnl operation - formerly ICE - was a new development: a majority of former employees chose to leave the sold company, and some returned to jnl. After having found legal modus to continue our activity, the company was divided into two parts. jnl, on the one hand, continued its missions of specialized mandates. On the other hand, Phoenix, an entity re-born from its ashes, took over all operational activities: internal audit, compliance, agreement and relations with the CSSF and the Ministry of Finance, coaching and training. I am only a manager at Phoenix to support its development and promote its success. As for jnl, I am more involved in "personal" missions, in particular by focusing on directorships in companies supervised and unsupervised by the CSSF.

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