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.

Read article

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?

Read brochure

Last April, IMS Luxembourg, the Societal Movement Institute in Luxembourg, was launched.

IMS Luxembourg had been announced since 2006 with a governmental support. It was said to be the result of the combined will of various large private sector partners concerned with promoting Corporate Social Responsibility (CSR). Members of the press, public sector, various companies as well as notable figures involved in sustainable development both in Luxembourg and the Greater Region were invited to celebrate the association’s official launch on April 20 by IMS’s Management Board.

The occasion allowed two guest speakers - one from the Ministry of Economy and one from a French rating agency - to voice their thoughts on sustainable development including the opportunities facing companies today.

The founding members of the institute - Arcelor Mittal, AXA, Dexia-BIL, KNEIP, Noble & Scheidecker and PricewaterhouseCoopers – presented themselves as companies strongly involved in implementing CSR policies.


"We look forward to seeing you at our upcoming IMS Luxembourg events that will consist of breakfast meetings and thematic discussions on Corporate Social Responsibility." the press release concluded.


What upcoming events ?

The first event about private sponsorship took place in June without asking the critical question : To what extend the involvement in actions in the framework of a communicated Corporate Social Responsibility may be a way to hide poor governance and the absence of guilt trip in business, in other words a way to buy a good image that may not be deserved? Many companies involved a pollution scandal, in mobbing... have a webpage to communicate on their CSR. As far as the financial center is concerned, we could imagine money launderers that would launder part of the the money thanks to private sponsorship. This question is very important in a financial center and may be a risk for the reputation of those who receive the money and of course of the financial center.

A new event relating to diversity was planned to take place in October 2007: it was actually never scheduled. Furthermore there is no events scheduled since the first one.

Over six months after its launch with a strong communication (5 articles in the media), the institute unfortunately appears to be an empty shell as there are no breakfast meetings and thematic discussions on Corporate Social Responsibility.



Am I exagerating? Let's have a look on a recent press release from Dexia about sustainable development. Dexia provided the chairman of the Board of the association that is ignored in the press release af if it did not exist. It was quoted in June.


I am sad to see that the Ministry of Economy as official support and the chairman of auditors as member of the board (besides the potential conflict of interest because of the proximity with companies audited in such venture, as if his involvements due to his role of chairman of auditors were not time-consumming enough) were involved in a body that is actually not living, which is not a surprise. I could have told them not to go. Despites my requests for a meeting since a couple of years I was never invited.

In the small center where everybody support everyone I am less frequentable than companies that hire and support knowlingly dishonest and non competent members of the senior management, refuse to hire rigorous employees, do not tell the truth at the tribunal... while communicating on their integrity, their professionalism and of course their ... CSR.




Read press release relating to the launch

Read press release relating to the first event (in French)