Head of Compliance
Hi Renata, could you tell us a bit about your background and role at Generali Investments Luxembourg?
I joined Generali Investments Luxembourg S.A. as Head of Compliance Officer/MLRO in July 2015.
Before moving to Generali Investments Luxembourg S.A., I was Senior Legal & Compliance Officer at BSI Fund Management S.A., prior to which I was a member of PwC Luxembourg’s Governance, Risk and Controls Department. While at PwC, I was a member of PwC’s Fight Against Financial Crime task force and an expert in general compliance matters with over 14 years of international experience in the insurance and asset management industry.
Before joining PwC, I was Head of Compliance at a leading Management Company in Luxembourg where she was in charge of strategic, tactical and operational compliance matters for the Company.
Prior to this, I gained over 12 years of experience in the cross-border life insurance industry (as Head of Compliance). In 2000, I joined Luxembourg’s largest cross-border life insurance company and in 2009, I decided to join an international insurance group to set up and develop the Compliance Department in its bancassurance branch in Luxembourg.
I am represented at local Compliance and AML associations in these areas on a regular basis and provides dedicated training in the area of AML/CTF and regulations.
At TSAM London you’ll be participating in the opening panel discussion in the Regulations & Compliance forum: The Firm-Wide Regulatory Battle: Finding the Formula for Effective Communication. For Generali, you are based in Luxembourg, whilst other main offices are based in Italy, the UK, and elsewhere across the globe. Do these geographies ever have a significant impact on compliance communications?
It can become a challenge at times although with today’s technology such as video conferencing, it is easy to stay in touch and have face-to-face discussions with our colleagues in other offices around the globe. On occasion, details do get “lost in translation” but you learn to overcome these issues by analysis the legal text with your colleagues in different languages to see exactly what the meanings of the regulations are. Group Compliance is supportive in helping each subsidiary with the interpretation and implementation of the multitude of compliance regulations.
What would be your top two tips of advice for maintaining effective communication throughout the business when it comes to compliance issues?
It is now over a month since MiFID II came into fruition. How have Generali coped with the demands so far?
Generali Investments Luxembourg’s Investment funds, Generali Investments Luxembourg as Management Company and AIFM are in principle excluded from the scope of MiFID II. However, MiFID firms are servicing the entire fund industry up and down the value chain. MiFID II is therefore not without impact on our Luxembourg fund range and GIL as Manco.
For this reason, we have prepared EMT’s for all our funds which we provide to our distributors. We provide our distribution network with information for full transparency through the Fund’s EMT which details costs related info., target markets, type of investor, knowledge of the investor, how long the investor should keep the fund to be fruitful, etc. If there is a new sub-fund, we would issue a new EMT and on an annual basis, we review each EMT and re-issue.
We relied on various service providers and on the support from the Group to meet the deadline and finalize the project.
Many are calling MiFID II the most revolutionary regulatory shift for generations. Do you believe this will be the case – or are there more significant disruptions on the horizon?
Certainly, one can consider this regulation revolutionary since providing Increased transparency of markets, orderly trading behaviour within markets, more explicit costs of trading and investing as well as a shift in trading towards more structured market places. We manage the impact by carrying out additional initial and ongoing due diligence. Other significant regulations which are on the horizon are GDPR, BMR, EMIR, SFTR which, after implementation, compliance functions will need to monitor to ensure that all obligations of the new regulations have been respected.
Join Renata and peers from AXA Investment Managers, KBC Group, PGIM and EFAMA for their panel discussion on The Firm-Wide Regulatory Battle: Finding the Formula for Effective Communication at TSAM London on the 13th March 2018. Visit https://www.tsamlondon.com/ for more details and to book your place.