Luxembourg legal update — March 2013
Arendt & Medernach has released the March 2013 edition of its Luxembourg legal update.
On 16 January 2013, the Commission de Surveillance du Secteur Financier (the CSSF) published the circular letter 13/556 (the Circular Letter) announcing the entry into force of the CSSF Regulation No. 12-02 of 14 December 2012 on the fight against money laundering and terrorist financing (the Regulation). In addition, the Circular Letter repeals and replaces (i) the former circular letter 08/387 on the fight against money laundering and terrorist financing and prevention of the use of the financial sector for the purpose of money laundering and terrorist financing, as amended (the Circular Letter 08/387) as well as (ii) the former circular letter 10/476 on the fight against money laundering and terrorist financing, which has abrogated and amended certain provisions of the Circular Letter 08/387…
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Section 2 of CSSF Regulation No. 13-02 relating to the out-of-court resolution of complaints will enter into force on 1 July 2014.
‘Allowances’ used as part of the fixed remuneration targeted by the European Commission, co-legislators and the EBA
The practice of introducing ‘position or role-based allowances’ is one of the elements underlined in the detailed analysis of EU banks published by the EBA.