What are the key projects you have been involved in over the past twelve months?

Three projects stand out. The first was the implementation of a series of regulatory changes affecting, among other areas, our market data business. The evolving European framework on market data required us to review how we structure, document and commercialise our data offering. The legal team’s role was to translate the new requirements into revised policies and contractual terms, working closely with the commercial teams so that legal compliance and product development were fully aligned.

The second was DORA. Beyond the internal governance work, the major effort for the legal team was the renegotiation of the agreements with third-party IT service providers to reflect the new contractual requirements for ICT services. This was a substantial exercise, and it materially strengthened the contractual set-up on audit rights, incident reporting and exit arrangements.

The third is data protection, which has taken on renewed importance in times of digitalisation and AI transformation. As new tools enter the organisation, ensuring that personal data is processed lawfully and transparently is no longer a back-office exercise but a condition for innovating responsibly. The outcome across all three projects is the same: regulatory change absorbed without disruption to the business, and in several cases turned into an opportunity to modernise the frameworks.

Can you describe an instance where your legal advice directly influenced business strategy or commercial objectives?

Technology, and distributed ledger technology in particular, is a personal passion, and it has given me the opportunity to shape strategy rather than merely vet it. I contributed a few years ago to the drafting of the first guidelines on the registration of digital assets on LuxSE’s Securities Official List. This was genuinely new terrain: there was no established template for how a market operator should approach natively digital assets. The legal analysis of what would be important for investors to know about these digital instruments effectively defined the contours of the offering. Legal work can help position the exchange early in a market segment that continues to develop.

What key trends should in-house counsel be monitoring over the next six to twelve months?

The trend I would single out is data management, which is becoming an increasingly difficult topic due to the sheer number of parallel regulatory evolutions: eIDAS II and the European digital identity framework, the AML package, the AI Act, alongside the existing data protection acquis. Each of these frameworks pulls on the same underlying resource: data. At the same time, we are seeing the creation of centralised data hubs at European level, centralising information and making it publicly available. For in-house counsel, the challenge is no longer analysing each regulation in isolation but understanding how they interact across the organisation’s data architecture and flows.

How do you navigate situations where legal advice and commercial objectives conflict?

My first step is always to clarify the situation for all participants, to establish whether we are genuinely in a conflict, which is not always the case. Most of these situations are not a true clash between law and commerce, but rather cases where the legal assessment itself is difficult to carry out due to a lack of clear rules, case law or doctrine. Framing them honestly as questions of legal uncertainty rather than opposition changes the conversation entirely. What is of utmost importance is that the legal team understands the business and its priorities. That understanding is what allows us to find workable alternatives, and, where a judgement call is unavoidable, ensure the decision process is properly documented so the organisation can stand behind it.

Beyond your legal role, is there a cause or initiative you are especially passionate about?

Two causes, in fact: financial literacy education and corporate governance. On the first, we welcome many student visitors at the exchange, and I find these encounters genuinely energising. Explaining how capital markets work to the next generation is one of the most rewarding parts of the job. On the governance side, I serve as a board member of ILA, the Luxembourg institute of directors. In addition, as Secretary General of the Stock Exchange I am currently also involved in reviewing the X Principles of corporate governance together with colleagues and industry representatives. It is an honour to help in updating the standards that Luxembourg-listed companies will live by for years to come.