Calling all entrepreneurs ! One client can hide another - watch out for financial sanctions

Legal Affairs

Anne-Sophie Theissen, director Legal Affairs, Chamber of Commerce

On 25 September 2019, the Luxembourg Chamber of Commerce, in partnership with the Luxembourg Trade Confederation (clc), organised an awareness raising conference, Calling all entrepreneurs! One client can hide another – watch out for financial sanctions, in order to keep stakeholders informed about the implications of the draft law n°7395 that aims to reform and provide a more precise framework for the implementation of financial sanctions.

This conference, which was aimed at a wide audience, was thus intended to raise awareness about possible risks in order to better prevent them. Participants were provided with recommendations for further reading in order to learn more about certain elements so that they can, if necessary, take action with their own advisors.

The morning was divided into three parts and was presented by Mr Gérard Zolt; Ms Polyxeni Kotoula and Mr Arsène Jacoby; and Ms Sundhevy Debrand, respectively.

The first part, presented by Mr Zolt, Associate Partner, Country Practice Leader – Forensic & Integrity Services, at Ernst & Young, provided an overview of the financial sanctions, the ramifications and the challenges, but also the opportunities, specifying that it is not a question of trade barriers but of calling attention to the fact that certain rules must be respected, which are specific to the country being dealt with and the competent authorities concerned. Some risky behaviour, in particular faulty identification of customers or dual-use items, was addressed.

In the second part of the morning, Mr Jacoby and Ms Kotoula, from the Ministry of Finance, explained good practices they expect in terms of reporting transactions on a European and international level.

For the third part of the morning, Ms Debrand, Chief Compliance Officer & MLRO at Quilvest and Board Member at ALCO (Association of Luxembourg Compliance Officers), shared her personal experience and provided practical advice that shed light on theoretical principles that are not always clear, particularly in terms of audits.

The CLC and the Chamber of Commerce would like to thank the presenters and participants for their interest and engaged presence that contributed to an interesting and constructive conference.