The President’s message

Our association recently celebrated its tenth anniversary. It may therefore be worthwhile recalling, for the most recent members, the objectives fixed by the fourteen Compliance Officers who established the cornerstones of the ALCO at its first general assembly of 20 December 2000. The association’s objective is to bring together Compliance Officers – and in general people with compliance responsibilities – from the financial and insurance sectors in Luxembourg. It endeavours to promote communication and the exchange of ideas between its members through regular meetings, through their participation in internal or external working groups, and by organising conferences and debates on professional ethics and compliance issues within the financial sector in the Grand-Duchy of Luxembourg. Its aims also establish contacts with foreign associations which have similar objective.

The working groups (WGs) set up by ALCO are one of the key elements of how the association operates. When the association was formed, various working groups were entrusted with the task of preparing its basic documents, namely the Compliance Charter, Compliance Policy, the Code of Good Conduct and convergent AML interpretations. Some WGs have become permanent structures, for example those which manage the quarterly production of the ALCO Newsletter and the training provided by ALCO instructors to Compliance Officers to help them prepare for their certification examination. Recent issues such as salaries in credit institutions and the Compliance Officer’s position in the bank organisation charts have led to ad hoc WGs being set up. Each working group is composed of volunteers from among the association’s 530 members.

To promote exchange between its members, ALCO organises conferences as well as specialised events and more informal meetings. It publishes its Newsletter on the ALCO website which, in the section reserved for members, shows the results of the roundtables and of the Professional Ethics WG, as well as questions and answers that are likely to be of interest to the majority of visitors.

Following a dignified tribute to the founders, ALCO’s tenth anniversary was also an opportunity to take stock of the huge changes that have occurred over the last ten years as regards the role and responsibilities of Compliance officers in the financial sector in Luxembourg. In 2000, the fight against money laundering mainly involved regularising client identification procedures and monitoring financial transactions and the origin of funds, solely for drug trafficking related infringements. 2001 was the year of what is now known as Ground Zero and the CSSF, set up in December 1998, began extending predicate offences for money laundering, starting with the fight against terrorist financing and now covering all criminal offences punishable by a deprivation of liberty of at least 6 months. Since then, there has been a spate of laws, regulations and circulars extending to all sectors of financial activities: the domiciliation of companies, UCI, the institutionalisation of the Compliance function, derivative products, prospectuses, IT outsourcing, support FSP, SICAR (venture capital investment companies), capital adequacy, market abuse, SIF, MIFID, ICAAP, transparency requirements for issuers of securities, liquidity risk, the AGDL (Deposit Guarantee Association), UCITS IV, salaries. In addition, we are now awaiting new regulations which will be introduced by the three European authorities established on 1st January 2011.

There is therefore still a lot of work ahead for Compliance Officers who now face an increasingly heavy workload. ALCO will continue to pursue its objectives and will do its utmost to promote exchanges of opinions and ideas between its members. Members are also encouraged to contribute in person to this effort in so far as their circumstances permit.

Your President

/ Bulletin22 / Newsletter 22 (Décembre 2011)

Essai des étudiants bénéficiaires de la bourse ALCO

• Tin- The New Blood Diamonds?
•  Cross-border compliance: the double-edged sword of banking secrecy”

 Le GT Tables Rondes:

• Des tables rondes, pourquoi faire ? -Bilan et projets-
• Résumé de Table Ronde : Third country AML  

Rapport du Groupe de Travail ALCO – GT36

• Lignes directrices concernant les politiques de rémunération dans le secteur financier (circulaires CSSF 10/437, CSSF 10/496, CSSF 10/497 et CSSF 11/505) : Introduction

Questions de membres

•  What is your approach to apply CSSF 02/77 to non UCITS Funds ? Have you had feedback from the CSSF on this subject?  

•   Lorsque un BE est un fond d'investissement :- Lorsque il s'agit d'une société cotée sur un marché financier                            Quels sont les documents et diligeances à effectuer (KYC) par le compliance officer.

ALCO in brief

Fight against laundering of money of criminal origin and against terrorism financing; integrity of financial markets, respect for ethical principles, all these are now important part of the financial sector today and that influences its activities widely.

The Compliance Officer function has appeared among credit institutions, PSFs, insurance companies. The Compliance Officer role is to make sure that these institutions comply with the current legislative, statutory and ethical standards.

Today, the Compliance function in the financial sector is officially recognised, on an international level by the Committee of Basel, and locally in Luxembourg by the CSSF. This function becomes compulsory in all the institutions of the financial sector in Luxembourg.

The "Association of Luxemburg Compliance Officers" for the Financial Sector was created as of 20 December 2000.

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ALCO brings together around 400 members who meet around varied activities: working groups, conferences and meetings.

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