Jean-Noël Lequeue (JNL): Twenty Years at the Heart of Compliance
Jean-Noël Lequeue, founder of JNL, looks back on twenty years of compliance evolution in Luxembourg, analyses the risks and opportunities for the financial center, and calls for a comprehensive audit of the regulatory system.
For those who don’t know you, can you describe JNL in a few words?
JNL is the culmination of a twenty-year career in the banking sector. After founding three or four companies—most of which I later sold—I chose to focus on what I call the core: the most challenging assignments. Specifically, this includes serving as a director—primarily in the financial sector—assisting clients in dealing with regulators to obtain authorizations or resolve specific issues, as well as handling applications for approval of new shareholders in the financial sector. This work naturally led me to pre-acquisition audits, both regulatory and financial. It’s a particularly interesting field, because a company’s value is no longer limited to its balance sheet. Its ability to be fully compliant—to adhere to all applicable laws—has become a central criterion for evaluation. The past ten years have radically transformed expectations: the European approach and that of the CSSF have evolved toward ever-greater oversight and sharply rising costs.
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“The value of a company isn’t just its balance sheet; it’s also its ability to be fully compliant.”
How is compliance evolving in Luxembourg today?
The compliance function is evolving positively. It is now recognized—having been enshrined in Luxembourg law for a good ten years—and its professionalization is essential. The ALCO, the Luxembourg Association of Compliance Officers, contributes significantly to this through its working groups and the documents it makes available to its members. That said, we are also seeing an explosion in demands and responsibilities. Teams are growing, which complicates the transfer of skills to younger staff. Salaries have risen sharply, but so have personal responsibilities: when it comes to AML, the consequences for an individual compliance officer can be very severe. The underlying problem remains the considerable increase in costs. Large organizations absorb these costs with less difficulty and even turn them into a competitive advantage to generate more revenue. Small asset management firms, on the other hand, are merging or acquiring one another to share costs they can no longer bear alone. This poses a real risk to competition and the diversity of offerings in the market.
What risks and opportunities do you see for Luxembourg?
The regulatory burden is growing exponentially, and there is no sign of it letting up. This pressure directly threatens SMEs in the financial sector, which are less well-equipped than large players to absorb the costs. The redundancy is colossal: horizontally, all parties involved with a single client repeat the same AML checks; vertically, first-line supervision, compliance, internal audit, the external auditor, the CSSF, and European regulators all pile on top of one another. That is why I advocate for a comprehensive independent audit to identify redundancies and reduce complexity. I do not know if this falls in the scope of the Court of Auditors or if it should be carried out by a large Business Consulting firm.Furthermore, the technological opportunities are real. Artificial intelligence and blockchain can profoundly transform the world of funds. Claude Marx himself has stated that he would not understand why AI isn’t used in AML. Nor would I understand why the CSSF does not use it for fund authorization and registration—a strategic issue for the Luxembourg financial centre.
FACTS & FIGURES
Birthday: 12/18/1946
Place of birth: Lincent (Belgium)
Nationality: Belgian
Children: 2
Languages: French, English, Flemish
MY FAVOURITE
Cities: Boston, London, Paris
Restaurants: Clairefontaine, Mosconi, Cristallerie
Places: Mountains, Villages and Sea
Books: Voyage dans la France d’Avant
Artists: Benoit Poelvoorde
POSITION: Managing Director
OTHERS: Member of boards of directors
AWARDS: Harvard University 2000