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Podcast: The revised CSSF circular 12/552 and what it means for banks

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Schmidt Carole
Carole Schmidt



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Costica Andrei
Andrei Costica

Senior Associate


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26 February 2021

Banks’ internal governance issues have, in recent years, received increased attention from regulators and international bodies, aimed primarily at correcting weak or superficial internal governance set-ups and practices.

In this context, the CSSF Circular 20/759 recently amended the CSSF Circular 12/552 on central administration, internal governance and risk management and aligned it with relevant European guidance (notably the EBA Guidelines on internal governance (EBA/GL/2017/11) and the Joint ESMA and EBA Guidelines on the assessment of suitability of members of the management body and key function holders (EBA/GL/2017/12).

Testimony to the importance of the topic in the coming years, the amendments made to the CSSF circular 12/552 go beyond mere cosmetic updates and:

  • clarify certain internal governance requirements applicable to banks;
  • define the scope of certain regulatory principles (such as the principle of proportionality); and not least
  • formalise the CSSF’s approach and practice in certain areas.

In this podcast, Henri Wagner, the head of A&O’s Luxembourg banking regulatory practice, is joined by Carole Schmidt and Andrei Costica, who are respectively counsel and associate in the firm’s Banking-ICM and Regulatory team, in an interactive discussion on the key amendments to the revised CSSF circular 12/552.


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