Ethics and governance in the European Financial centers

Pit Reckinger from the Law Firm Helvinger, Hoss & Prussen drafted an article to be published in a slightly shortened version by Anti Money Laundering: International Law and Practice, W. H. Muller, C. H. Kälin and J. G. Goldsworth (Eds), Copyright John Wiley & Sons Ltd, 2007.

See article

In its last Newsletter the association PRiM (Professionals of Risk Management) focuses on people risk.
The goal sounded interesting: "although discussions on operational risk have become commonplace since the late 1990’s, the topic of people risk, which is actually a part of operational risk, has received relatively little attention. Far too often financial service providers assume that people risk is a human resource issue and therefore do not give it the risk management attention it deserves. For this reason, the eighth PRiM Risk Newsletter focuses on people risk"
So sounded interesting the contributors list: articles on people risk from Arnaud Jouanneau, Head of Internal Audit, CapitalatWork Group and President of the Luxembourg Institute of Internal Auditors (IACI) and Gilbert Renel, Partner, Deloitte Consulting and Advisory; an interview with Viviane Harnois, Head of Human Resources, ABN Amro Bank; Samuel Grand, Head of Operational Risk Management, ABN Amro Bank; John Li, Managing Partner, KPMG; Michael May, Managing Director, HSBC Securities Services and Laurent Vanderweyen, Chief administration Officer, RBC Dexia Investor Services.

Unfortunately they did not focus on actual issues relating to people risk for a financial centre.

When reading the newsletter, it appears that the word “growth” is quoted 13 times. But keyword relating to people risk are missing:

Social words relating to employees like “strike”, “social”, “conflict”... are not quoted. The current conflict between the ABBL (The Luxembourg Bankers Association (ABBL) is the professional organisation of most of the banks established in Luxembourg and also of other financial sector operators) and Unions relating to the collective bargaining demonstrates that Luxembourg is no longer the place with no social conflicts it used to be, which is definitely a threat for the reputation of Political Economic and Social Stability of the centre.

Furthermore critical keywords for a financial centre are missing “ethics”, “ethical”, “deontology”, integrity....

They did not quote any judiciary examples of fraud that are not confidential to illustrate.

The only contributor that saves the level is Gilbert Renel from Deloitte, who quoted sensitive words relating to employees: “fraud” (7 times), “honest” (once), “honesty” (once), « dishonest » (once).

The words “honest” and “dishonesty” are quoted once each in the editorial conclusion.

The word « fraud » is quoted once in a question from PRiM, and to answer, 3 times by Michael May and once by Viviane Harnois, both to minimise the phenomenon.


Professional ethic is not sought in recruitments. The disreputable character is not the dishonest employee, but the one who ask question about dysfunctions and/or who is not a yes person (see article : "The average employee in a bank is a sheep either white or black")

See Newsletter

The IRE in Luxembourg, which is the regulatory body for auditors, has initiated an ambitious project to reinforce AML in the Luxembourg financial centre.
The project, which is called "Side Safe Watch", is in the framework of the KYC requirements.

Side product, SafeWatch, allows automated Anti-Money Laundering (AML) checking on the complete financial flow, regardless of origin and transport through a fully configurable and scaleable enterprise solution, strengthening AML compliance.
SafeWatch helps in preventing emission of outgoing and processing of incoming messages/data referring to black listed entities. The enterprise server can simultaneously analyze a large variety of sources: text files, real-time flows, SWIFT messages, MQ Series, Database tables... all detections are sent to the central SafeWatch monitoring station, and users are automatically notified of alerts by e-mail.

The application emphasizes on enterprise-wide features:
• Complete auditing
• Strong security management
• Full reporting

This project is developed by external auditors (and chartered accountants) in independence with their auditees that are not invited in the project group.


See information