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Magazine Issues » September 2020

Luxembourg: The "heavy process" of anti-money laundering

Funds Europe – How well has the Luxembourg funds industry coped with working from home?

Grenner – I’ve been quite amazed at how quickly everybody switched to home working and how quickly work resumed as if it was being done in the office, whether via company laptops or home computers. I think it has worked for probably the majority of people quite smoothly. The objective was that the client would not notice any difference, and – with a couple of exceptions – this has been achieved. In companies where time is recorded against client accounts, working time is traceable and trackable, and that has helped to prevent employees from disappearing into ‘nirvana’ for a day or so. Team managers and supervisors have also adjusted ways of working.

In practice, 35% of staff could go back to the office now. If we get something between 10% and 20%, it’s because people think they can do the same work more efficiently and happily from home.

Thommes – There are certainly some critical functions where firms asked their people to have a look at it and partially work from the office, maybe on the IT side, maybe on certain risk functions. Given the fact that people have to have business continuity plans in place, they could quite reasonably and efficiently execute those.

From a market perspective, investors didn’t panic or overreact. We had a drop in overall assets, but in the meantime we have seen over the last three months very positive inflows of money. Obviously, assets in the market went up as well, we had governments and central banks providing substantial monetary support, trying to mitigate some of the impacts, so overall we weathered the storm and the early stresses reasonably well.

It’s true what Anja said, that maybe people have seen the benefit from working from home, so that’s a top priority in many firms, to see how can we strike the right balance. 

Mouftaou – In Luxembourg, we are quite lucky as we are living in a highly connected jurisdiction with a solid IT infrastructure. This has made it possible for employees to work not only from home but across country borders. 

In addition, business continuity plans – which are mandatory for all regulated firms – have been activated in most cases with success.

All of these factors have made us resilient to the crisis. We have found a new balance and this is going to go on for many months yet.

Brimeyer – The first two to three months were almost painless, except for the first week where we moved everyone home. 

After a while, you realise working from home is fine, but there are situations where you need your colleagues around. We continue to recruit a lot of people, so how are you going to onboard someone if you have an empty office? How do you integrate people into the teams? How do you ensure that you have efficient coaching/supervision of the juniors? These are topics that we are looking into so that we are ready for the new world where more tele-working will be happening. I think there have been challenges but not, as you would maybe have expected, early on in the crisis. 

One topic that is quite an unknown for us is the tax and social security issues that non-resident employees may have (they represent more than 60% of our talents). Exceptions have been granted by governments from neighbouring countries during the crisis, but these will not last for ever. Will we therefore have the required flexibility to implement more home working? We have proven that as a market, we have the flexibility, but if governments go back to the initial rules, it might force more people back to the office than we would like. We need to be pushy on this topic so that we have sufficient flexibility to shape this. 

Thommes – Work is being done internally or domestically to see how we can put a framework around this, because there are numerous topics to address. The CSSF is also looking into this. Firms are not returning with their entire teams to the office in the very near future, and beyond that, they might try to find arrangements that comply with existing regulations. If existing regulations have to be adjusted, I think there is a willingness at least to address it.

The financial industry played an important role in limiting the spread of the disease because we could quite quickly move to work from home.