General counsel | Banque Internationale à Luxembourg (BIL)

Frédéric Sudret
General counsel | Banque Internationale à Luxembourg (BIL)
What are the key projects you have been involved in over the past twelve months?
The sale of BIL Group’s fund management company to Waystone and outsourcing part of the internal IT function to Kyndryl were key projects.
What key trends should in-house counsel be monitoring over the next six to twelve months?
Cybersecurity is becoming a key topic for in-house counsel. The current legal regime will change (most likely as of 2027), as PSD3 is expected to significantly increase the potential liability of financial intermediaries. The transformation of the legal function with AI is also another key topic, including the creation of dedicated AI agents for specific workflows, e.g., to facilitate the drafting of replies to customer claims.
As geopolitical instability continues, alongside economic and technological change, how do you guide your organisation through periods of uncertainty?
Geopolitical instability risks are primarily addressed through a close monitoring of the bank’s risk appetite and the development of specific crisis scenarios. This topic is not driven by the GC in our group but by the Risk Management function. At our level, we focus on communicating in a transparent manner and on stabilising and reassuring the staff.
How has the role of general counsel evolved, and what are the most important attributes for the modern in-house lawyer?
The role of the GC, but more widely of the legal function, in some of the Luxembourg banks is not as important as what it used to be from my point of view – on the regulatory side, the focus in recent years has indeed clearly shifted towards the internal control functions, i.e., Risk Management, Compliance and Internal Audit. The GC and legal team still play a key role in protecting the bank and in handling some of the complex issues that these functions cannot manage.
How do you navigate situations where legal advice and commercial objectives conflict?
This is one of the most exciting parts of the GC’s role. The key is to identify the legal risk, then to assess if and how it can be managed and if the residual risk is acceptable. The legal team has a veto right on some decisions and is represented in the key internal committees of the bank.
How have you implemented AI within your legal team to improve efficiency while maintaining quality and governance – and keeping the human element?
We are well-advanced in the selection of an AI provider for the legal functions but are still considering whether it would not make more sense to implement a tool on a bank-wide basis and to deploy it thereafter to address our legal needs. We are convinced that the human element will remain key once AI is implemented and the workflows adapted, but it is difficult to assess the future impacts that this will have on the control functions.
Organisations are facing increasing regulation across jurisdictions. How do you embed compliance across the business?
We use an external provider to make sure that our regulatory roadmap is up to date, and we have a dedicated Regulatory team that coordinates the implementation of such regulations for the Group.
In which areas does compliance most commonly break down, and how do you address these risks?
Compliance can typically break down due to system or process failures. As of early 2026, we have introduced an escalation process at the level of the first line of defense and Claims Management team to escalate any such issues that they may detect at their level, to Management for further handling.
How do you promote ethical decision-making beyond formal compliance requirements?
Risk culture is a key topic for the bank, also for the ECB. It is promoted throughout the bank through regular risk culture surveys, trainings on ESG and governance, and direct messaging from the top, including the management body, etc.
Beyond your legal role, is there a cause or initiative you are especially passionate about?
I was thrilled to have been appointed recently as a Board member of the Luxembourg Banking Law Association (ABBL), which has more than 800 members in Luxembourg and which promotes legal doctrine and legal education in Luxembourg.
Secretary general and general counsel | Banque Internationale à Luxembourg (BIL)