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Paul Wagner

Senior Associate

As an IP, Data & Tech lawyer, Paul advises clients on a wide range of matters related to the digital and data-driven economy, such as online advertising, connected devices, cloud outsourcing, telecommunications, and privacy issues at the workplace. 

He helps clients comply with data protection and cyber-security rules, negotiate software development and IT contracts, develop their internal governance and compliance programs, apply for licenses, and prepare for the latest legal developments and trends, for example in the field of artificial intelligence. His practice covers both contentious and non-contentious matters, and he has defended clients in investigations by data protection authorities, both before the authorities themselves and in court.

Paul works with a diverse clientele in the financial and insurance sectors, the funds sector and the technology sector. He collaborates closely with legal counsel and IT teams to understand the technical aspects of the issues and the client's business needs. He has a cross-sectional vision of the law and a pragmatic approach, combining his expertise with a strong background in Luxembourg civil and administrative law.


Representative matters

A global technology company on a large-scale investigation by the Luxembourg data protection authority. Paul defended the client on various aspects of data protection and Luxembourg administrative law, working with various teams both within and outside the firm.

A financial institution on a service agreement with a software developer and multiple other parties for an artificial intelligence platform to support a collaborative and investment-syndication program. Paul advised on the transfer and licensing of IP rights, data protection, cybersecurity and business continuity requirements.

An investment advisor and private credit firm on the structuring and setting up of a Luxembourg based fund. Paul ensured the fund's compliance with Luxembourg data protection requirements, including data transfers, and reviewed and negotiated the data protection clauses and disclosures in the agreements with the service providers. 

A global technology company on the licensing as an electronic money institution in Luxembourg. Paul delivered comprehensive guidance on the IT outsourcing and cybersecurity requirements and advised on the use of personal data for training machine learning models for anti-money laundering purposes.

A British bank on the implementation of various IT monitoring tools. Paul draft a comprehensive memorandum, covering various aspects under Luxembourg data protection and privacy laws, and the outsourcing and banking secrecy requirements in the Luxembourg financial sector.

Published Work

  • Di Lorenzo, C., Ancenys, L.-A., Wolters Ruckert, N., Wagner, P., (2024), “EU AI Act: Key changes in the recently leaked text”, London: A&O
  • Wagner, P., (2023), “GDPR-CARPA: A look at the GDPR's first certification mechanism”, Luxembourg: Legitech
  • Di Lorenzo, C., Wagner, P., (2019), « L’arrêt Buivids et les limites de la liberté d'expression face à la protection des données », Luxembourg : Legitech
  • Di Lorenzo, C., Wagner, P., (2019), “Cookie consent - How to get it (right)”, Luxembourg: Legitech

Speaking Engagements

  • Guest Speaker, Generative AI and the AI Act in Banking, LHoFT – Luxembourg House of Financial Technology, November 2023
  • Speaker, Upcoming implementation of the EU Whistleblowing Directive, Allen & Overy in collaboration with The British Chamber of Commerce for Luxembourg, October 2022

Leadership Positions And Professional Affiliations

  • Advised a Luxembourg non-profit organization that provides social and professional integration services on the legal requirements for obtaining and publishing the images of the participants in the organization’s events, in light of the rights of publicity and privacy.
  • Advised a Luxembourg start-up that is developing a local peer-to-peer lending platform, where individuals can lend and borrow items for each other, in setting up their terms and conditions.



Luxembourg, 2021


LL.M., Law and Technology, UC Berkeley, 2017

Master, Economic and Social Law, Université Libre de Bruxelles, 2016

Bachelor, Civil Law, Université Libre de Bruxelles, 2014


A&O Shearman was formed on May 1, 2024 by the combination of Shearman & Sterling LLP and Allen & Overy LLP and their respective affiliates (the legacy firms). Any matters referred to above may include matters undertaken by one or more of the legacy firms rather than A&O Shearman.