ABBL-Annual Report 2021
ABBL-Annual Report 2021
2021
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2 Annual Report 2021 SECTION 1: A WORD FROM OUR CHAIRMAN
The banking sector is the driving force of the Luxembourg economy. The financial
sector provides direct employment for over 50,000 people, half of which are in the
banking sector. Together we create almost 25% of the GDP and contribute over 35%
of the tax revenues to the state coffers. Banks provide funding for businesses, loans
for housing, investment products for wealth planning and pension provision, and a
whole range of services to keep the economy turning. But we also all know that the
world does not stand still, and as financial professionals, we have to move with the
times, prepare for the future and adapt to changing circumstances every day.
When I was elected Chairman of the ABBL in 2018, we could not have imagined the
events of the last two years. Who would have predicted the covid pandemic, the
sheer magnitude of which has changed our behaviour and galvanised our priorities
in a way that the financial crises of the past did not? Having to jump to a modus
operandi of distance working overnight, finding new ways to stay in touch with our
clients, supporting those clients through the economic downturn, keeping our own
staff engaged and motivated, these were all challenges that we were not expecting
and were not at all prepared for.
And now we find ourselves in the middle of a political crisis, with the Russian
invasion of Ukraine forcing us to rethink our priorities once again. Instability brings
with it volatility, never the economy’s friend, and whilst implementing sanctions
is part of our daily business, it nevertheless brings with it added workload and
complexity. The humanitarian consequences do not bear thinking about. Many of
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our members are highly engaged in fund raising efforts to provide humanitarian
aid for refugees, and those efforts are to be applauded, but we also know that the
conflict will not be over anytime soon, and the long-term consequences are so far
unquantifiable.
Throughout all this external turmoil, we must somehow stay focused on our
A WORD FROM
business, and most importantly, focus on the future of our sector. We must ensure
that we build a sustainable future for the banking sector, that we continue to create
value in the economy, that we invest in our young talents, that we support the
OUR CHAIRMAN transition to greener energy, and that we continue to digitalise our services, so that
we can look to the future with positive energy and confidence.
3 Annual Report 2021 SECTION 1: A WORD FROM OUR CHAIRMAN
The ABBL, is very well-aware of this. Over the last 2 years we have spent time As a financial sector covering many different types of business, we are stronger
reorganising our team, re-focusing our efforts, streamlining our communication together, and under the umbrella of PROFIL, which brings together all the financial
towards our members, and attempting to become more efficient. We have reviewed sector stakeholders, we have identified some common priorities to articulate to
our priorities and worked on upskilling our team to ensure our members are being those running for office in the next government. Some of those common priorities
served in the best positive way. We have continued to increase our membership, include measures to help attract and keep talent in Luxembourg, to have a fiscal
and our current level of membership is the highest it has been for 20 years. framework which will keep us competitive, to avoid gold-plating EU regulations and
These are good building bricks for the future, but we still have work to do! maintain the agile, innovative development of the legal toolbox that has helped us to
be a frontrunner in financial services in the past.
We must be proactive. The banking sector has survived the covid pandemic without
too much lasting damage, and this is mainly because we were proactive. Domestic If the Ukrainian crisis has highlighted anything, it is that our reliance on fossil fuels
banks came together quickly, with the support of the ABBL and the CSSF, to agree a is still the dominant force in the energy economy. The European Union sources
common approach on moratoria and lending during the initial stages of the health around 46% of its coal, 40% of its natural gas, and 27% of its oil from Russia. Energy
crisis. Our advocacy towards the government on the treatment of cross-border independence means a transition to renewable energy. It is estimated that around
workers paid off, with temporary exemptions to enable working from home, and 5% of global GDP will be needed to finance the transition towards a green economy,
we were able to coordinate your questions towards the CSSF to help create clear and that will be down to the banking sector to provide that financing. We must
guidelines on a whole variety of topics related to handling data and reporting understand the economic, financial, and regulatory arguments to justify a harder
deadlines. We also know that the more robust balance sheets we were forced to put push towards sustainable finance. Waiting for regulations to force us into action will
in place after the 2008 financial crisis provided a very useful cushion to help absorb simply not work, once again, we need to be proactive. The best quantification of
the economic downturn of 2020/21. the financial impact of climate risk considers the two possible risks involved in the
journey: physical risk - associated with the climate change process itself, the risk of
After a short hiatus at the beginning of 2020, the regulatory machine in Brussels natural disasters, fires and floods - and transition risk, associated with initiatives to
picked up its pace again, and we have done an enormous amount of advocacy at EU slow down the process. Putting numbers to the financial derivatives of climate risk
level to ensure that the Luxembourg perspective is heard. We are actively working on should increase our appetite for financing operations aligned with a low-carbon
the EU banking package and the AML package, banking and capital markets union, future.
on MiFID and AIFMD reviews, the consumer and mortgage credit directives and a
range of payments and digital files like MiCA, DORA and instant payments as well as The same applies to digitalisation: we need to harness all the opportunities
fiscal files. Our key battle cries in Brussels remain proportionality, a level-playing offered by the use of technologies in finance while also addressing the risks to
field and measured regulation. financial stability or investor protection that these technologies can pose. We
must have the necessary frameworks in place to manage the massive changes
Looking forward, we will focus on advocacy more in the home market. We absolutely that come with technical innovation, from the handling of crypto currencies to
need to get our collective message to the right people at the right time. In 2023 we will the mutualisation of AML information.
have government elections, and this is an opportunity to put forward our concerns.
4 Annual Report 2021 SECTION 1: A WORD FROM OUR CHAIRMAN
“We will do
the customer experience, reducing costs and increasing mid- and back-office
efficiency. The next steps are open banking, which should boost the development
of innovative financial solutions for retail and corporate customers based on open
data sharing across sectors. Open banking should be seen in the wider context of
everything that we
an open data economy, where users are at the centre and decide when, with whom
and for what purpose to share their data held by different sectors. Open access to
public sector APIs allowing banks to access certain public data, taking real advantage
have a sustainable,
of training available at all levels to develop talent for the financial sector.
“
The ABBL strives to be a forward-looking association. We will continue to keep our
members informed, to speak out on their behalf, to defend their interests and to further
the interests of the financial industry. In short, we will do everything that we can to
help keep the sector strong and ensure that we all have a sustainable, long-term future.
Guy Hoffmann
long-term future.”
Chairman of the ABBL
5 Annual Report 2021 SECTION 2: THE BANKING SECTOR IN NUMBERS
The Luxembourg
financial sector
comprises 124 banks,
and a whole host of other
financial institutions
and organisations which
support the sector.
The sector is an economic
driving force for the local
economy, contributing
somewhere between
02
25-30% of GDP, and
contributing over 35%
of tax receipts (source
CES). The banking sector
THE BANKING SECTOR alone provides direct
employment for around
IN NUMBERS 26,000 people.
6 Annual Report 2021 SECTION 2: THE BANKING SECTOR IN NUMBERS
BILLION EUR
970
EU 81 78 73 73 70 815 863
746 769
Europe
22 21 20 20 19
(non-EU)
Rest of the
36 36 34 35 35
World
42% (4,886) 42% (4,986) 45% (5,380) 42% (5,061) 36% (4,890)
40% (4,706) 42% (4,959) 42% (5,109) 47% (5,038) 50% (5,931)
18% (2,166) 16% (1,741) 13% (1,560) 11% (1,401) 14% (1,903)
7,000 35
MILLION EUR
5,505 5,101
6,000 5,073 30
4,782 4,608 23
5,000 4,044 23
3,722 3,703 25 21
3,654 18
4,000 3,091 20 16
3,000 15
2,000 10
1,000 5 53% 57% 61% 62% 60%
2017 2018 2019 2020 2021 2017 2018 2019 2020 2021
Before tax & provisions Net result Ratio % Banks with > 100% ratio
28,000
27,000
26,317 26,334
26,145 26,059 25,964
26,000
25,000
The ABBL is the oldest and largest employers’ association in Luxembourg, with 177 full
Members, and 60 related Members representing each segment of the financial sector.
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Total titular members 177
Related members 60
OUR MEMBERS Our FinTech Circle, a specific grouping created with the objective of bringing
together financial services FinTechs with our Members, now counts 20 companies,
with new companies joining all the time.
10 Annual Report 2021 SECTION 3: OUR MEMBERS
03 MEMBER RELATIONS
Representing such a wide range of members, and being active in many different areas, it is important to be able to relay
information to the right people, to ensure that members active in a particular business are aware of developments
specific to their area, and that our actions are aligned across the various groupings within the association.
The Member Relations team is the first point of contact for members, onboarding new members, and cultivating
relationships with existing members. This is also the team that takes care of our conferences and expert events,
bringing topical subjects to the attention of members and facilitating opportunities for a valuable exchange of
information.
6 9 25
EVENTS
2,305PARTICIPANTS
expert events expert events in
co-operation with a member
8 2
on the sector, today and in the future. It brings together the ABBL
Banking Clusters, which represent the main businesses of the
Luxembourg financial sector: corporate & institutional banking,
depositary banking, private banking and retail banking.
speakers / panelists at networking events
external events for members
11 Annual Report 2021 SECTION 3: OUR MEMBERS
In 2021, the ABBL and PwC Luxembourg published a Corporate Banking Survey.
The survey aimed to collate answers from CEOs and CFOs of corporate banks in Luxembourg. The objective was to
assess the sector, identify current and future challenges and opportunities, as well as map out a clear path for
enhancing Luxembourg’s competitiveness in this banking segment.
The survey showed that Luxembourg indeed boasts a truly international corporate banking
landscape. Compared to other countries where corporate banks only serve domestic businesses, what we see in the
Grand-Duchy is a unique network of corporate banks from various countries, serving both local and – to a large extent –
international companies in both the financial and non-financial sectors.
Amid the plethora of banks and business models that were surveyed, three distinct segments were identified namely:
the local banks which mainly serve a diverse set of local companies in financing and cash management services, EU
banks which provide financing solutions to European NBFIs and multinational corporations, and non-EU banks which
meet the financing and trade finance needs of non-EU companies for their operations across Europe.
12 Annual Report 2021 SECTION 3: OUR MEMBERS
3,09
2,16 2,52
1,94 1,87
03 DEPOSITARY BANKING
The cluster represents banks active in depositary & custody services and acts as a main reference point for interactions
on depositary and custody activities with authorities and other stakeholders.
The main cluster activities for 2021 covered the following actions:
Finalization of the survey template to carry out a market study in cooperation with the CSSF to collect broader market
data among all depositary banks in Luxembourg. This essential data aids the development of business intelligence
around depositary banking and custody services through research indicators, advocacy activity and promotion.
The survey will be officially launched by the CSSF mid-April 2022.
Publication of the ABBL/ALFI guidelines (joint event Q1-2021)
ABBL response to the AIFMD consultation launched by the European Commission (Q1-2021)
ABBL response to the Outsourcing consultation launched by the CSSF (Q3-2021)
Member guidance note on the practical application and implementation of the fund audit end-of-year inventory
process (Q2-2021)
Engaging in partnerships with relevant actors of the Luxembourg depositary banking ecosystem was also important
for achieving the cluster goals inside and outside of Luxembourg. In 2021, the main external partners supporting these
activities were ALFI (via the common ABBL/ALFI Depositary Banking Forum) and LPEA (Luxembourg Private Equity
Association) invited as speaker at our DBCL ExCo to present the LPEA PE/VC Depositary Services Technical Committee
(Q1-2021)
14 Annual Report 2021 SECTION 3: OUR MEMBERS
03 PRIVATE BANKING
The cluster regroups professionals active in private banking and wealth management
with the primary objective to advocate and promote the private banking industry, both
level with AuDs now standing at 35% above the level reached in 2017. While the market effect
partly explains this development, the increase nevertheless remains considerable.
within Luxembourg and abroad. In a fast-changing market and regulatory environment,
the qualification and professionalism of our members is our priority and key mission. By The development of third-party managers creates healthy competition between market
promoting standards, practices, ethical and deontological norms we strive to continuously players, which benefit the client, as well as the entire Luxembourg sector. To date, the
progress. assets managed by these independent managers (Luxembourg PSF and foreign players
with equivalent or comparable licenses) represent 10% of the private banking assets
CSSF / ABBL Private Banking Survey held in Luxembourg.
One of the highlights in 2021 was the latest CSSF / ABBL Private Banking Survey. Creation of a dedicated platform for Investment Firms (WG IF)
AUM: Assets under management in Luxembourg reached a total of €508BN by the end Independent asset managers are a growing section of the ABBL membership, and to ensure
of 2020. This is a 126% increase since 2008 (€225BN); a doubling of assets, the result of 12 that they have a platform, the ABBL has just launched a working group dedicated to the
consecutive years of growth community of investment firms (IFs) that are PSF regulated entities supervised by the CSSF.
Wealth bands & number of accounts: Clients with assets over €20M represented 58% of
total AUM at year end of 2020. The number of clients with assets of less than €1M continues The objectives of the ABBL’s IF working group are:
to decrease (only 7% of total AUM in 2020).
Geographic analysis: In terms of geographic origin of assets, Europe undoubtedly is the To develop ideas, in synergy with the other ABBL groups, in particular those active in
core market (85% of total AUM) the Private Banking arena
Employment: The private banking sector employed 6,097 people in 2020 (6,131 in 2019) Promote the exchange of best practices
Population: 54 banks, representing over 95% of the private banking industry in Luxembourg Monitor and exchange on legal, regulatory and relevant industry trends
Speak with one voice to stakeholders such as the CSSF and the Ministry of Finance
CSSF / ABBL External Asset Managers Survey 2021 (WG EAM)
Since 2017, the ABBL, with the support of the CSSF, collect data surveys on independent
asset managers business sector with a view to gain a solid statistical database.
The 2021 survey shows that assets under deposit rose by 19% compared to the previous year,
reaching €53Bn as of 30/06/2021, witnessing a consolidation of the sector at a respectable
15 Annual Report 2021 SECTION 3: OUR MEMBERS
03 PRIVATE BANKING
The private banking sector attracts international, high net worth clients. There are over 50 private banks
in Luxembourg, located here because of the stable political climate, the excellent rating of the country,
the sophisticated and international workforce, and the extensive financial ecosystem which supports the
full range of cross-border wealth management needs. Our annual survey of the private banking landscape
provides key insights on the development of the sector to our Members. The sector employs over 6,000
staff and serves clients from many different countries. Over the last few years, we have seen a significant
consolidation in the sector, a shift in the client whilst assets under management continue to grow apace.
2020 508
15% 15%
03 RETAIL BANKING
The cluster aims to defend professional interests of ABBL members active in retail banking,
and to foster an exchange of ideas on a range of topics relevant to the sector.
The Cluster has also participated in the consultation process of the following
regulatory topics:
Consumer credit
During 2021, the cluster performed its annual Retail Banking Survey in collaboration with Mortgage credit
the CSSF. The credit institutions participating in the survey represent over 90% of the retail
banking business in Luxembourg. Retail Banking clients are private individuals and SMEs. The European Commission (EC) has issued a proposal for a new directive on consumer
The figures stated are as 31 December 2020. credits. The aim is to take into consideration the impact of digitalisation on the new
consumer habits and the emergence of new market players. The EC focus is among others
Overall, the Retail Banking sector has handled the pandemic well. Massive efforts were on the extension of the scope of application of the directive, additional pre-contractual
made to continue to service clients, despite many obstacles, and the local retail banks came information requirements, stronger rules on creditworthiness assessment, possible
together to agree terms for ‘covid loans’ and worked with the government to create special introduction of caps on interest rates, APRC and total cost of credit. Besides, the EC is
state- guaranteed loans to support businesses during the pandemic. undertaking an evaluation process of the current mortgage credit directive focused on pre-
contractual information, creditworthiness requirements and early repayment.
The Luxembourg retail banking sector is worth around € 92.4 billion (assets and liabilities
combined), representing an increase by 9.3%, demonstrating that clients continued to
borrow during 2020, mainly for real estate projects.
03 RETAIL BANKING
The retail banking sector in Luxembourg serves a wide range of clients, from private individuals,
professionals, SMEs but also private banking and corporate clients. The main business is
lending, with over 80% of loans dedicated to real estate purchases.
90,107
83,659
MILLION EUR
MILLION EUR
79,317
71,838
67,863
41,012 44,533
35,232 37,860
32,909
2017 2018 2019 2020 2021 2017 2018 2019 2020 2021
18 Annual Report 2021 SECTION 4: ABOUT THE ABBL
We provide our Members with the intelligence, resources, and services they need
to operate in a dynamic financial market and in an increasingly complex regulatory
environment. We also facilitate an open platform to discuss key industry issues and
to define common positions for the entire sector.
We are organised around four main pillars, dedicated to the banking sector of today
and of the future: Sustainability & Conduct, Digital & Innovation, Member
Relations and Regulatory Affairs. With this structure, we facilitate a transversal
approach, with our Member Relations team acting as the interface between the ABBL
experts and ABBL Members, ensuring that efforts are always focused on issues that
have the biggest impact on the sector, today and tomorrow.
The ABBL is also part of a much larger eco system, and we work closely with
partner associations in the wider economic environment, as well as national
04
and international bodies and committees, including the Haut Comité de la Place
Financière (HCPF), the Luxembourg Financial Supervisory Authority (CSSF), the
Luxembourg Central Bank (BCL), the Luxembourg Employers’ Federation (UEL),
the Luxembourg Stock Exchange, the Economic and Social Council, the European
Banking Federation (EBF), the European Covered Bond Council and the European
Payments Council (EPC).
THE ABBL our European Affairs team closely follows regulatory developments, interacts with
policy makers and represents the interests of ABBL Members in Brussels.
19 Annual Report 2021 SECTION 4: ABOUT THE ABBL
04 GOVERNANCE
BOARD OF DIRECTORS
04 GOVERNANCE
BOARD OF DIRECTORS
Status as of 28 March 2022
Pierre Ahlborn Claire Alexandre Julie Becker Béatrice Belorgey Stanislas Chambourdon
BANQUE DE LUXEMBOURG S.A. PAYPAL (EUROPE) S.À R.L. BOURSE DE LUXEMBOURG BGL BNP PARIBAS S.A. KPMG LUXEMBOURG,
ET CIE, S.C.A. SOCIÉTÉ COOPÉRATIVE
Olivier Chatain David Claus Colette Dierick Falk Fischer Luc Frieden
CA INDOSUEZ WEALTH (EU) S.A. EUROEAN DEPOSITARY BANK ING LUXEMBOURG S.A. BANK JULIUS BAER EUROPE S.A. CHAMBRE DE COMMERCE DU
GRAND-DUCHÉ DE LUXEMBOURG
Arnaud Jacquemin Riccardo Lamanna Marcel Leyers Philippe Renard Frank Rückbrodt
SOCIÉTÉ GÉNÉRALE STATE STREET BANK BANQUE INTERNATIONALE À RBC INVESTOR SERVICES DEUTSCHE BANK
BANK & TRUST INTERNATIONAL GMBH LUXEMBOURG S.A. BANK S.A. LUXEMBOURG S.A.
Thorsten Schmidt Philippe Seyll Françoise Thoma Massimo Torchiana Emanuele Vignoli
NORD/LB LUXEMBOURG S.A. CLEARSTREAM BANKING S.A. SPUERKEESS INTESA SANPAOLO BANK HSBC CONTINENTAL EUROPE,
COVERED BOND BANK LUXEMBOURG S.A. LUXEMBOURG
MANAGEMENT BOARD
MANAGEMENT
TECHNICAL EXPERTS
TECHNICAL EXPERTS
Galina Miroschnichenko Marilyn Rinck Jessica Thyrion Antoine Van den Bulcke
DIGITAL & PAYMENTS FINANCIAL MARKETS FINANCIAL EDUCATION DIGITAL & PAYMENTS
26 Annual Report 2021 SECTION 4: ABOUT THE ABBL
SUPPORT FUNCTIONS
SUPPORT FUNCTIONS
Business Technical
Forums
Clusters Committees
05
Working
Groups
ACTIVITIES
IN 2021
29 Annual Report 2021 SECTION 5: ACTIVITIES IN 2021
Advisers at the ABBL monitor key topics and share knowledge around innovation and technologies destined to
revolutionise the sector, such as instant payments, artificial intelligence, blockchain technology, open banking,
big data, cloud computing and crypto assets.
We also play a key role in connecting the Luxembourg financial ecosystem: financial institutions, payment service
providers, e-money institutions, FinTechs, IT providers, consultants, law firms and academia as well as the
regulatory and public authorities, all come together in our various groups to exchange ideas and share their views.
The digitalisation of distribution models and internal processes is high on the agenda for banks, as online banking
services and online payments are increasingly used by customers and working from home is now a reality for many
employees. In this context, cybersecurity is even more of a priority, to protect against cyberattacks and preserve
consumer confidence.
The ABBL closely monitors legislative proposals at European level concerning digitalisation and its impact on the
financial sector and works on position papers with regard to legislative proposals with a short and long-term impact on
digital finance and banking, such as Digital Operational Resilience (DORA), Markets in Crypto Assets (MiCA) and
Distributed Ledger Technology (DLT) in financial services.
30 Annual Report 2021 SECTION 5: ACTIVITIES IN 2021
05 EUROPEAN AFFAIRS
The European Affairs team, based in Brussels, represents the interests of the ABBL towards the EU
institutions and monitors developments at EU level of importance to ABBL members.
The office was set up in 2006, and is shared with the Luxembourg fund industry association, ALFI. Both
associations joined the Transparency Register in the year of its creation in 2008.
Published on 27 October 2021 by the Commission, the proposed Banking Package 2021 aims to finalise
the implementation of the Basel III Accord in the EU. The package also contains EU-specific parts on
sustainability and supervision. The package, which is subject to review by the European Parliament and
the Council of Ministers, is expected to be adopted in late 2022 or 2023.
Proposed implementation of the 72.5% production floor Banks will be required to take ESG risks into account in their Supervisors will have more powerful tools to supervise EU
very close to the literal interpretation. risk management systems. banks, including complex banking groups.
Specific provisions for exposures to unrated companies, The issue of adjusting capital requirements for green or brown Minimum standards will be introduced to supervise third
low-risk mortgages and derivatives. assets has been raised, but has not yet been answered, country branches of non-EU banking groups.
Alleviation of compliance costs, especially for smaller banks. pending a specific assessment due in 2023.
32 Annual Report 2021 SECTION 5: ACTIVITIES IN 2021
05 REGULATORY AFFAIRS
With increasingly complex and constantly evolving regulations, it is vital that banks and
financial institutions understand the implications of these changes before they happen,
to our financial community. The high number of participants, over 500, showed the interest
of the banking community in the topic.
and that they have a strong voice to represent their interests. ABBL advisers closely monitor
changes in regulations and directives, articulating a balanced position, based on the views of FAIR IMPLEMENTATION OF THE REGULATION ON OUTSOURCING
all our members, towards legislators and regulators as they are created. The ABBL contributed to the CSSF’s public consultation on their circular on outsourcing
arrangements, calling for a fair implementation of the EBA’s 2019 guidelines. In particular,
The Regulatory Affairs unit is working on banking regulations, financial markets regulations, the ABBL raised the need to ensure an effective supervisory approval process, adequate
taxation and banking and financial law. The team closely monitors relevant legislative materials recognition of intra-group outsourcing and consistency between the numerous national
as they are created with the aim of articulating a balanced, measured view towards lawmakers regulatory texts dealing with outsourcing.
and regulators alike. The team coordinates the work of the following ABBL technical committees:
Accounting Committee DEFENDING DEPOSITARY BANK ACTIVITIES
Banking Supervision Committee In the context of the AIFMD review, the ABBL signaled its opposition to any extension of ESMA’s
Financial Markets and Intermediation Committee direct supervisory powers over AIFMs to the European Commission, as well as to the introduction
Fiscal Affairs Committee of a depositary passport, which would have very negative impacts on business in Luxembourg.
Legal Affairs Committee
Securities Committee BANKING UNION: KEEPING THE SUBSTANCE AND MINIMISING COST
The ABBL defended the strategic interests of the banking sector within the EBF and with the
These groups gather excellent subject matter experts to collate and present position papers, European Commission, in particular:
to develop implementation guidelines and to support our members with advice and best
practices in an ever more complex environment. Exchange on regulatory exemptions for capital requirements, to keep the substance in our banks
Minimise the cost of a European Deposit Insurance Scheme (EDIS) for our banks
Banking Regulation Minimise the impacts of extending the crisis management framework to smaller EU banks
CIRCULAR CSSF 12/552: CLARIFYING MEMBERS’ QUESTIONS, WITH THE CSSF Financial Markets
Following the update of CSSF Circular 12/552, which regulates the central administration,
internal governance and risk management framework of banks, the ABBL and the CSSF have ABBL POSITION ON THE EUROPEAN FRAMEWORK FOR RETAIL INVESTOR PROTECTION
drafted a Q&A based on questions collected from ABBL Members. This Q&A was presented The ABBL has actively participated in the discussions around the European Commission’s
during a joint webinar, during which the CSSF answered a wide range of questions posed by Action Plan on Capital Markets Union, the latest development being the consultation on a
ABBL Members, illustrating the quality of the dialogue with the CSSF and the value it brings retail investment strategy to which the ABBL has responded.
33 Annual Report 2021 SECTION 5: ACTIVITIES IN 2021
05 REGULATORY AFFAIRS
The European Commission also invited the European Securities and Markets Authority (ESMA)
to provide advice on retail investor protection, the review of the MiFID II framework on best
FOR THE ADOPTION OF THE COVERED BONDS DIRECTIVE
In the context of the transposition of the EU Covered Bonds Directive, the ABBL has
execution reports and the Regulation on Retail Investment Products and Insurance (PRIIPs). been actively advocacy for the adoption of the Covered Bonds Directive.
ESMA was asked to consider the adequacy of current regulatory requirements, focusing on the
effectiveness of protection, and the potential opening of value chains through the sharing of Tax Dossiers
certain investor data between investment firms and third-party providers.
The ABBL, together with ALFI and ACA, has been consistently advocating for
Overall, the ABBL supports investor protection as an essential element. However, it should successive extensions through 2021 of special tax and social security arrangements with
not be forgotten that clients are responsible for their own financial investments and neighbouring countries regarding telework for cross-border workers, thus avoiding
that investor protection should not become financial paternalism. A clear, concise, and negative implications for both employers and employees during the pandemic.
coordinated regulatory spectrum is needed to support clients in their decisions, not restrict Discussions were also initiated, together with the Luxembourg Employers' Association
them. Similarly, the technological shift towards digitalisation, especially considering that (UEL), with the French authorities regarding the French withholding tax on salaries.
Open Finance is the next step on the road to Open Banking, should focus on equal care for While these discussions are still ongoing and have not yet yielded conclusive results,
the customer and be based on fair treatment of old and new stakeholders. this initiative helped the French authorities to understand the concerns of employers in
Luxembourg regarding the implementation of this new regime under French law. Going
JOINT MARKET INFRASTRUCTURE WORKING GROUP forward, we inted to provide input, together with UEL, to the recently-initiated discussions at
The ABBL has set up a joint working group with the Luxembourg Capital Markets Association OECD level regarding the tax consequences attached to cross-border home working with a
(LuxCMA) in 2021, to advance hot topics in market infrastructure, such as T2/T2S, the view to ensure a balanced outcome for employers in Luxembourg.
European Collateral Management System, the debt issuance market and benchmark reform
and regulation. The working group kicked off on 21 January 2022 with a meeting on the The ABBL has contributed to industry input at international level regarding the
regulation of Central Securities Depositories. treatment of banking groups in the context of the OECD-led reform of the international tax
system. As a result of this work, sensible alleviations are foreseen for regulated financial
AGAINST THE EXTENSION OF ESMA’S DIRECT SUPERVISORY POWERS services. As the legal texts are currently being finalised, we are further engaging with the
In the context of the Capital Markets Union, the ABBL has reiterated to the European Government to ensure that the final rules properly address the specificities of financial
Commission its strong opposition to any extension of ESMA’s direct supervisory powers. services providers.
Such an extension would indeed considerably harm the attractiveness of the Luxembourg
asset management and depositary banking sector. Finally, we ensured continued monitoring of tax issues affecting our members both in
their capacity as taxpayer and employer, with a particular focus on new incentives in the
field of personal taxation and the VAT treatment of company cars.
34 Annual Report 2021 SECTION 5: ACTIVITIES IN 2021
The ABBL continued to advocate for enhancements to the legal framework applicable to
financial transactions with a view to consolidate the status of Luxembourg law as a law
of reference in the field of international finance. Concrete steps in 2021 involving ABBL
input related to (i) the release of draft legislation containing sensible enhancements to the
legal framework applicable to financial collateral arrangements and (ii) a proposal towards
a review of legal restrictions applicable to the capitalisation of interests in commercial
contracts. Further work and engagement in 2022 will relate to (i) the finalisation of a
standard facility agreement under Luxembourg law, (ii) active participation in the
current review of the Luxembourg civil code launched by the Ministry of Justice, with a
focus on contract law and collateral arrangements, and (iii) preparatory work towards the
transposition of the EU directive on non-performing loans. In this context, we would like to
underline the effectiveness of our Law Firm Forum, which serves as a think tank for the
elaboration of relevant industry proposals.
deontology. It monitors social affairs issues in order to accompany HR departments in the RAISING AWARENESS AND DEVELOPING EXPERTISE IN SUSTAINABLE FINANCE FOR
abundance of new regulatory issues in the field of labour law. Finally, it develops numerous BOTH THE GENERAL PUBLIC AND FINANCIAL SECTOR PROFESSIONALS
actions in the fields of financial education and Corporate Social Responsibility.
Development of a module on the basics of sustainable finance, which then provides
The Sustainability Committee aims to engaging strategic dialogue with its Members and closely access to the other modules of the sustainable finance training programme for
monitor sustainable finance developments. It also serves as a knowledge sharing platform and finance professionals. In collaboration with Deloitte and the House of Training.
ensure adequate coverage and communication about the main topics for Luxembourg Banking
sector, including corporate social responsibility and financial education areas. Participation in the European Finance Summit in March 2021, with a discussion
on sustainability goals for the financial sector and hosting a conference on the new
The Committee has several Working Groups dealing with specific topics and provides generation of financial leaders.
information to the Compliance Forum and the Data Protection Forum.
Participation in the HEC Paris MBA and the University of Luxembourg’s Sustainable
Sustainability Finance programme, where the ABBL shares its expertise on the impacts of ESG factors
on the banking sector.
The Renewed Strategy for Sustainable Finance published by the European Commission (EC)
in July 2021 and the COP 26 in Glasgow in November 2021 led to a series of declarations, Series of videos on responsible finance for the general public - in collaboration with
policy proposals and initiatives to bring about practical changes in the agenda of the ABBL Foundation.
governments, policy makers, regulators, businesses, and financial institutions to support a
fair and sustainable transition.
To address the new challenges and developments that have emerged, the ABBL revised its
governance in 2021 to reflect the priorities of its Members: ESG Financial Markets, ESG Risks
task force, Taxonomy and Labels, Corporate Sustainability and Financial Education and Training.
Sustainable finance is one of the ABBL’s key priorities, and we are focusing our efforts on
consistent and pragmatic policies and practices so that banks can effectively play their role in
climate and sustainability. Here are the achievements in 2021.
36 Annual Report 2021 SECTION 5: ACTIVITIES IN 2021
PRIORITY 2
05 SUSTAINABILITY & CONDUCT
PRIORITY 3
PROMOTE CORPORATE SOCIAL RESPONSIBILITY (CSR) AND IMPROVE PRACTICES CHANNELING FINANCIAL FLOWS TO SUSTAINABLE ACTIVITIES
Production, in collaboration with Forethix, of a practical CSR guide dedicated to the Publication of the guide “ESG Financial Markets: A Luxembourg Implementation Guide
banking sector, which provides the basis for a responsible strategy and an overview of to the Sustainable Finance Disclosure Regulation (SFDR)”, in collaboration with ALFI
best practices. The guide is accompanied by a CSR self-assessment tool and a glossary. and ACA, which analyses the requirements of the SFDR to assist in the implementation
of the SFDR rules.
Regular contribution to the European Commission’s consultations and requests from
the government and the European Banking Federation on the proposed Directive on Publication of a white paper on the integration of climate and environmental risks into
Corporate Sustainability Reporting, as well as on the proposed initiative on the risk management frameworks of banks in Luxembourg. The paper provides an
Sustainable Corporate Governance. overview of current regulatory expectations and highlights the practical challenges and
some of the approaches banks have used to overcome them. In collaboration with Deloitte.
The ABBL has launched a survey on CSR and sustainable finance practices in the
banking sector, the consolidated results of which should be shared by the end of June Feedback to the government on the proposed European Green Bond Label, as
2022. In collaboration with Mazars. well as on the proposed texts to adopt delegated acts on the European taxonomy of
sustainable economic activities. The ABBL also actively participated in the joint UNEP
Signing of the UN Women’s Empowerment Principles and the partnership initiated FI and European Banking Federation report on “Practical approaches to the
by the European Banking Federation and EY through which European banks commit application of the European Taxonomy to bank lending”.
to sharing best practice on DE&I.
Supporting the launch of the National Business and Human Rights Pact in July
2021, encouraging ABBL Members to become signatories in view of the forthcoming
publication of the European Directive on Due Diligence and Corporate Responsibility.
The ABBL has joined the UN Net Zero Banking Alliance, which aims to achieve net zero
emissions by 2050.
37 Annual Report 2021 SECTION 5: ACTIVITIES IN 2021
Professional Obligations
05 SUSTAINABILITY & CONDUCT
Social Affairs
AML Signing of the new collective labour agreement for banks: protecting jobs and supporting
AML/CFT package: the ABBL closely monitors developments and defends the interests of the future of the financial centre.
the banking sector.
After lengthy discussions in a complicated social context due to a disunited trade union front,
The AML/CFT package is mainly focused on two EC legislative proposals, relating to: the negotiations for the 2021-2023 collective labour agreement reached an agreement, signed
The prevention of the use of the financial system for money laundering and terrorist on 10 June 2021. The interests of all parties have been considered, both for the companies in
financing (AMLR). the banking sector and for the employees, establishing a sound basis for the coming years.
The establishment of a European Anti-Money Laundering Authority (AMLA).
WHAT IS NEW IN THE AGREEMENT?
The ABBL advocates at national and European level, in particular on the following issues: While the new agreement largely builds on the previous one, it includes updated financial
conditions and, most importantly, changes related to work-life balance and social issues, including
AMLR the right to disconnect for employees using digital tools for work purposes and measures related to
On the pitfalls of over-regulation telework, such as compensation for costs related to regular non-crisis telework.
National legislators cannot go beyond the EU harmonised rules by adopting additional
specific national rules on top of those provided for by the AMLR. The agreement also includes the granting of 5 days social leave per year. As the modalities
There must be a level playing field between Member States, AMLA should only adopt have to be negotiated with the staff delegation, the ABBL has created guidelines for its
additional AML/CFT rules. Members to guide them in the discussions.
On the retention of records of financial transactions: we believe that the FATF standards and In order to clarify the changes and new provisions, the ABBL organised a Q&A session for its
the GDPR rules on proportionality and purpose should be respected and transactions should Members in June 2021.
be retained for at least 5 years after the transaction.
NEW PROVISIONS FOR REMUNERATION POLICIES
On the adjustment of due diligence requirements for embedded legal persons: To prepare Members for the transposition of the Capital Requirements Directive (CRD5) which
the definitions are too broad. took place at the end of 2021, the ABBL organised a conference on the impact of the directive on
remuneration policies. ABBL experts were joined by panelists from the CSSF, Allen & Overy and KPMG.
AMLA
1) The financing of this new supranational EU authority The changes concerned the lowering of the significant risk-taker threshold to EUR 50,000 in
2) Drafting powers (RTS/Guidance): too many and still unknown, must not deviate from AMLA rules. relation to annual variable remuneration, as well as the requirement for gender-neutrality of
remuneration policies, both for significant risk-takers and for all staff. The new provisions also
concern retention bonuses and disclosure requirements, which have been strengthened.
38 Annual Report 2021 SECTION 5: ACTIVITIES IN 2021
05
Financial Education: Consolidation of our initiatives
SUSTAINABILITY & CONDUCT
ONLINE BANKING TRAINING FOR SENIOR CITIZENS
Through its Foundation, our association was actively involved in the development of an
Financial education is part of ABBL’s strategy and commitment to act as a socially “E-Banking” training program for senior citizens initiated by the Ministries of Digitalisation and
responsible actor towards society. The ABBL raises awareness and promotes financial Consumer Protection in collaboration with the CSSF. This course, set up by the association
education among its members and stakeholders to help them enhance the financial “Erwuessebildung” (as a specific module or as part of the „Internet Führerschein“) was launched
empowerment of their customers and the wider community. in September 2021 and will continue in 2022. The aim of this initiative called “Ech kann dat
och” (“I can do that too”) is to allow elderly citizens to autonomously use their own e-banking
In 2021, our association, in collaboration with the ABBL Foundation for Financial Education, platform in a safe environment and is part of a national effort for the social, financial and digital
its partners and its members, reinforced its commitment to educate everyone on the basics inclusion of all citizens.
of personal finances management and financial literacy in general. All of our programmes
are carried out thanks to the involvement of volunteers, who are either employees of the Some figures
ABBL or employees of our members.
Woch vun de Suen
AWARENESS PROGRAMMES FOR CHILDREN ABOUT RESPONSIBLE MONEY MANAGEMENT 25 classes - 396 pupils - 32 volunteers
Each year, we organise the Woch vun de Suen (Money Week) dedicated to pupils aged 10 to
12. Understanding the value of money, teaching them to manage their pocket money and help European Money Quiz
them understand the importance of managing a budget are the priorities of this initiative. 3 classes
The ABBL also coordinates the European Money Quiz in Luxembourg. This online event aims Zuumer Academy
to promote financial literacy among teenagers in a Europe-wide competition. 3 sessions - 39 participants - 29 volunteers
This initiative was recognised at the IMS (Inspiring More Sustainability) Diversity Awards in
the “Recruitment, Reception and Integration” category. This award aims to honour specific
initiatives and share the best practices in terms of diversity management within organisations.
39 Annual Report 2021 SECTION 6: DIRECTORY OF MEMBERS
06 DIRECTORY
OF MEMBERS
(AS AT 31 MARCH 2022)
40 Annual Report 2021 SECTION 6: DIRECTORY OF MEMBERS
CATEGORY A
BANKS
Advanzia Bank S.A. CA Indosuez Wealth (Europe) Hauck & Aufhäuser Lampe Privatbank AG, Niederlassung POST Luxembourg
Agricultural Bank of China (Luxembourg) S.A. CaixaBank Wealth Management Luxembourg S.A. Luxemburg Quintet Private Bank (Europe) S.A.
Allfunds Bank S.A.U., Luxembourg Branch China Construction Bank (Europe) S.A. HSBC Continental Europe, Luxembourg Rakuten Europe Bank SA
Andbank Luxembourg China Everbright Bank (Europe) SA Industrial and Commercial Bank of China (Europe) S.A. RBC Investor Services Bank S.A.
Banca March, S.A., Luxembourg Branch China Merchants Bank Co., Ltd., Luxembourg Branch ING Luxembourg RCB Bank Ltd, Luxembourg Branch
Banco Bradesco Europa S.A. CIBC Capital Markets (Europe) SA Intesa Sanpaolo Bank Luxembourg SA Royal Bank of Scotland International Limited,
Banco Santander (Brasil) S.A., Luxembourg Branch Citco Bank Nederland N.V., Luxembourg Branch Itaú BBA Europe SA, Luxembourg Branch Luxembourg Branch (The)
Bank GPB International S.A. Citibank Europe plc, Luxembourg Branch John Deere Bank S.A. Skandinaviska Enskilda Banken AB (publ), Luxembourg
Bank Julius Baer Europe S.A. Clearstream Banking S.A. JP Morgan SE, Luxembourg Branch Branch
Bank of China Limited Luxembourg Branch Commerzbank Finance & Covered Bond SA Keytrade Bank Luxembourg S.A. SMBC Nikko Bank (Luxembourg) S.A.
Bank of Communications (Luxembourg) S.A. Compagnie de Banque Privée Quilvest S.A. Landesbank Baden-Württemberg, Luxembourg Branch Société Générale Luxembourg
Banking Circle S.A. Credit Suisse (Luxembourg) S.A. Lombard Odier (Europe) S.A. State Street Bank International GmbH,
Bankinter Luxembourg S.A. Danske Bank International S.A. Mediobanca International (Luxembourg) S.A. Zweigniederlassung Luxemburg
Banque BCP S.A. DekaBank Deutsche Girozentrale, Succursale de Mirabaud & Cie (Europe) S.A. Sumitomo Mitsui Trust Bank (Luxembourg) S.A.
Banque de Commerce et de Placements S.A., Luxembourg Mitsubishi UFJ Investor Services & Banking (Luxembourg) SA Svenska Handelsbanken AB (Publ), Luxembourg Branch
Luxembourg Branch Delen Private Bank Luxembourg S.A. Mizuho Trust & Banking (Luxembourg) S.A. Swissquote Bank Europe SA
Banque de Luxembourg Deutsche Bank Luxembourg S.A. Natixis Wealth Management Luxembourg The Bank of New York Mellon S.A./N.V., Luxembourg
Banque de Patrimoines Privés DNB Luxembourg S.A. Nomura Bank (Luxembourg) S.A. Branch
Banque Degroof Petercam Luxembourg SA DZ Prrivatbank S.A. NORD/LB Luxembourg S.A. Covered Bond Bank UBS EUROPE SE, Luxembourg Branch
Banque et Caisse d’Epargne de l’Etat, Luxembourg East-West United Bank S.A. Northern Trust Global Services SE UniCredit International Bank (Luxembourg) S.A.
Banque Havilland S.A. Edmond de Rothschild (Europe) Novo Banco S.A., Succursale de Luxembourg Union Bancaire Privée (Europe) S.A.
Banque Internationale à Luxembourg S.A. EFG Bank (Luxembourg) S.A. PayPal (Europe) S.à r.l. et Cie, S.C.A. VP Bank (Luxembourg) SA
Banque J. Safra Sarasin (Luxembourg) SA Elavon Financial Services DAC - Luxembourg Branch Pictet & Cie (Europe) S.A. Wüstenrot Bausparkasse AG, Niederlassung Luxemburg
Banque Raiffeisen, Société Coopérative Eurobank Private Bank Luxembourg S.A.
Banque Transatlantique Luxembourg S.A. European Depositary Bank S.A.
Barclays Bank Ireland plc, Luxembourg Branch Fideuram Bank (Luxembourg) S.A.
BEMO Europe - Banque Privée FIS Privatbank S.A.
BGL BNP Paribas S.A. Fortuna Banque s.c.
BPER Bank Luxembourg S.A. Goldman Sachs Bank Europe SE, Luxembourg Branch
Brown Brothers Harriman (Luxembourg) S.C.A. Hamburg Commercial Bank AG Luxembourg Branch
41 Annual Report 2021 SECTION 6: DIRECTORY OF MEMBERS
CATEGORY B CATEGORY C
PSF, E-MONEY & AUDITORS, CONSULTANTS,
PAYMENT INSTITUTIONS LAWYERS ETC.
Accenture (Luxembourg) S.à r.l. i-Hub SA 99 Advisory Luxembourg SA Finastra (Finastra Europe S.à r.l.)
Airbnb Payments Luxembourg S.A. LuxCSD S.A. AIQU Tax Sà rl Forethix Sà rl
Amazon Payments Europe SCA Luxembourg Stock Exchange AKD Luxembourg Sà rl Fundsquare S.A.
Bitstamp Europe SA LuxHub S.A. Allen & Overy S.C.S. Grant Thornton Advisory SA
BOS Wealth Management Europe S.A. LuxTrust S.A. Alpha Omega Sà rl GSK Stockmann S.A.
CapitalatWork Foyer Group S.A. Monex Europe SA Annerton SA Kleyr Grasso S.C.S.
Chambre de Commerce du Grand-Duché de Luxembourg Payconiq International SA Arendt & Medernach SA KPMG Luxembourg S.A.
Colin & Cie. Luxembourg S.A. Pemberton Asset Management SA ATOZ S.A. Linklaters LLP
Creditreform Luxembourg S.A. PPro Payment Services SA Avaloq Luxembourg S.à r.l. Loyens & Loeff Luxembourg S.à r.l., Avocats à la Cour
Creutz & Partners Global Asset Management S.A. Radices Financial Services S.A. Avantage Reply (Luxembourg) S.à r.l. Mazars Luxembourg SA
Dock Financial SA Satispay Europe SA AWK Group (Luxembourg) Sà rl Microsoft Luxembourg Sà rl
eBay Europe S.à r.l. Sopra Banking Software Luxembourg Baker & McKenzie Luxembourg Molitor - Avocats à la Cour S.à r.l.
Ekonoo SA Union Investment Luxembourg S.A. BDO Services Luxembourg S.A. NautaDutilh Avocats Luxembourg S.à.r.l.
Eurizon Capital S.A. Unzer Luxembourg SA BearingPoint Luxembourg Sà rl Norton Rose Fulbright Luxembourg S.C.S.
Finologee S.A. Worldline Financial Services (Europe) S.A. Bonn & Schmitt Sàrl PricewaterhouseCoopers, Société coopérative
Brucher Thieltgen & Partners, Avocats à la Cour Refinitiv SA, Luxembourg Branch
Castegnaro S.à r.l. Schiltz & Schiltz SA
Clifford Chance S.C.S. Simmons & Simmons Luxembourg LLP
CMS Luxembourg Stibbe Avocats
Deloitte General Services S.à r.l. Thomson Reuters Finance SA
Dentons Luxembourg Wavestone Luxembourg S.A.
DLA Piper Luxembourg Sà rl Westrich Gen SA
Elvinger Hoss Prussen, société anonyme Wildgen S.A.
EY zeb.rolfes.schierenbeck.associates GmbH
42 Annual Report 2021 SECTION 6: DIRECTORY OF MEMBERS
Contact
Association des Banques et Banquiers, Luxembourg
12, Rue Erasme
L-1468 Luxembourg
+352 46 36 60 - 1
[email protected]