Molitor Avocats a La Cour

Founded in 1996, MOLITOR Avocats à la Cour is a highly respected and independent law firm in Luxembourg City, a full-service firm which has grown over the years to comprise a staff of 50 people, including 31 lawyers, of whom nine are partners. Our lawyers are specialists in their chosen practice areas and they advise local, international and global corporate clients from across industry sectors in a wide range of corporate and commercial law matters, including Media, Data, Technologies & IP. Our firm is consistently involved in high-level local and international matters and we work closely with an ever-increasing number of top ranked international law firms on a variety of complex and high-profile issues. MOLITOR is recognised by the main Legal Directories. The Legal 500 EMEA recommend the firm for “combining practical experience with a very good knowledge of the law in Luxembourg, enabling the firm to provide a professional and high-quality service to clients from a range of industry sectors”. Michel MOLITOR, Managing Partner, is Avocat à la Cour and has been a member of the Luxembourg Bar since 1985. He has a law degree from the University of Strasbourg and a PhD in political sciences from the University of Vienna. Michel has over 30 years’ extensive experience representing local and international companies and advising clients on commercial law matters. Michel heads the firm’s Business & Commercial department. He is a renowned litigator and is highly experienced in advising domestic and foreign banks, insurance companies and other professionals in the financial sector on regulatory compliance issues. He is an active member of the International Bar Association (IBA), the Luxembourg Insurance and Reinsurance Association (ACA) and the European Employment Lawyers Association (EELA). He is consistently ranked by the main legal directories. In The Legal 500 he is ranked as a leading individual and praised for his “great standing in the market”. Clients describe him as a “seasoned lawyer with many years of experience” and say that he “always has a smart idea and solution to a problem”. Virginie LIEBERMANN, Counsel, is Avocat à la Cour and has been a member of the Luxembourg Bar since 2008. She holds a Masters in business law from the University of Strasbourg. Since 2017, she heads the Media, Data, Technologies &IP (M.D.T.P.) Team. Virginie provides advisory services to clients from a variety of sectors, including retail, automotive, health and financial. Her work focuses on advising on technology, including privacy laws and data protection, intellectual property law, media and advertising laws. She is a member of the Global Advertising Lawyer Alliance (GALA). In 2019, she was appointed as Board Member of the Association of the Information Society Professionals (APSI). The Legal 500 EMEA lists Virginie for her expertise in IP and IT. In 2019 they described her as “very capable on data protection matters” and in 2020, as “practical and responsive”.

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Michel Molitor

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Publications

• When the GDPR Clock Never Stops: Lessons from a EUR 175,000 Fine for Delayed Data Subject ResponsesIn a recent decision (n° 1FR/2025 of 6 January 2025), the Luxembourg National Data Protection Authority (the “CNPD”) sanctioned a major credit institution for non complying with access request’s deadlines as set by the GDPR- despite arguments of force majeure and operational challenges. The initial sanction suggested by the CNPD during the investigation phase to fine the credit institution amounted EUR 493,560 for the breach of Art. 12 (3) and (4) of the GDPR comprinsing 47 access right requests made by data subjects.10 July 2025
• Blockchain vs Data protectionAt first sight, blockchain technology and the General Data Protection Regulation (GDPR) seem to be intrinsically incompatible. The convergence of personal data protection and blockchain technology raises therefore complex issues surrounding data privacy and data protection issues.30 July 2024
• AI Act and GDPR: managing the world of data in the world of privacy.Contrary to some persisting beliefs that the AI Act and GDPR are inherently incompatible, GDPR may in fact be interpreted in a way that concords with the purposes of the AI Act. Processing personal data through an artificial intelligence (AI) system’s algorithm triggers the application of GDPR.24 October 2023
• Transparency in the sights of the Luxembourg data protection AuthorityAs in the past, the Luxembourg data protection Authority (the “CNPD”) launched in 2020 a thematic investigation on transparency (Article 12.1 of the GDPR). This investigation resulted in interesting and useful decisions of 13 December 2022 on the Authority's expectations regarding the application of the principle of transparency in the context of web services.9 May 2023
• Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law: what are impacts on data protection?Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law entered into force on 17 December 2021 in the Member States (the “whistleblowing Directive”). While the transposition of the whistleblowing Directive in the different member States is underway, this new regulation will impact companies’ business compliance. In terms of personal data protection, new challenges are already be anticipated.6 December 2022
• The use of CCTV in light of the Luxembourg National Commission for Data Protection’s sanctions.In 2021, the Luxembourg National Commission for Data Protection (the “CNPD”) issued 48 decisions following assessments. 18 of these 48 decisions related to non-compliance of CCTV systems deployed by the controlled entities. Recently, the CNPD issued again new decisisions to sanction entities using CCTV systems that were not compliant with the GDPR.14 July 2022
• Back to work: open sesame!The health situation in Luxembourg has been stable for several weeks now which allows for a possible return to a pre-crisis situation, in particular for companies. Athough teleworking should remain in the spotlight, companies are willing to see their employees again physically at work.1 November 2021
• Enforcement of the GPDR in Luxembourg: an issue at stake?Max Schrems and his organisation NOYB (None Of Your Business) have recently begun a new battle, taking place in Luxembourg! Legal proceedings have been issued against two decisions of the Luxemburg Data Protection Authority (the “CNPD”). These decisions dismissed two complaints lodged against two different US-based data controllers, Apollo and RocketReach. These claims are currently pending before the Luxembourg Administrative Court.14 May 2021
• Are fines imposed by the Luxembourg Data Protection Authority for breach of data protection regulations insurable?There is no shortage of recent examples of cyber-attacks and the current COVID-19 pandemic is undoubtedly contributing to an intensification of this phenomenon1. While such attacks can be devastating…12 February 2021
• DATA PROTECTION AND CORONAVIRUS: A difficult challenge for Businesses.In the context of the coronavirus pandemic, companies are implementing exceptional measures to protect the health and safety of their employees and clients. As a result of these measures, employers may collect new types of personal data, for example they might want to check whether employees have symptoms of the virus.3 September 2020