Ethics and governance in the European Financial centers

Lou Kiesch, from Deloitte, and Marco Zwick, from Schroder Investment Management, have recently published an article that presents the main innovations of the ALFI/ABBL/ALCO Practices and Recommendations aimed at reducing the risk of money laundering and terrorist financing.

One may find it strange that an investment fund, which is the auditee should publish with an audit firm.

But in this case, the auditor is PwC. Deloitte acts as an advisor.

This independance rule is therefore not impaired, which was not the case a couple of months ago when Deloitte published with the ABBL.

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PwC Luxembourg has started last month a series of training classes about "The Fight Against Financial Crime". This training was already organised once last year.

The agenda is excellent and cover a large scope of issues. As explained on the brochure ""this high-level training programme is aimed at professionals who fight against money laundering, the financing of terrorism, fraud and corruption, as part of their daily business. It has been specifically developed to respond to their lifelong learning needs and to keep their skills up-to-date. The different sessions offered address – from both a theoretical and
practical angle – issues such specialists are regularly confronted with but do not always find ready solutions to and provide an overview on latest developments and best practice."

It is interesting to observe that speakers are not from Luxembourg. The only professionals from Luxembourg is Rima Adas as moderator for one event. He is the Partner in charge or money laundering issues at PricewaterhouseCoopers Luxembourg which is a minimum. David Hagen from the CSSF (Commission de Surveillance du Secteur Financier) is speaker: he is the Head of IT Audit in charge of the assessment and
control of the IT systems of the entities falling under the supervision of the CSSF. This is not the most sensitive topic in the scope of the general programme.

But it is true that Financial Crime does not seem to exist in Luxembourg. PwC Luxembourg did not participate to the PwC Global Economic Crime Survey and did not found reasons to provide a specific country report

I wonder what is the use of having someone dedicated to money laundering issues and what is the use of providing such training for something that officially does not exist?

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