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Courses/ AML/CFT/ Module 4/ Lesson 4.5
Lesson 5 of 6 · Module 4

After the report, and the duty that runs the other way

Silence after a report is normal and it is not feedback. The published typologies, and the new article 5-1 that runs from the unit to you.

3:44 Module 4. Monitoring, suspicion and reporting to the CRF AML/CFT and KYC in Luxembourg practice
The video and the full transcript of this lesson are part of the course This page is the description of the lesson: what it is about, how long it runs and every instrument it is built from. Watching it and reading it word for word need an account with access to AML/CFT and KYC in Luxembourg practice. Two lessons of this course are open to everyone with no account and no payment.
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The narrated video runs about 1 hour 31 minutes across the 30 lessons. That is short on purpose: no filler and no reading out of the law, with the work in the transcripts, the sources, the assessments and the artefacts.

What Module 4 covers

Module 4. Monitoring, suspicion and reporting to the CRF

Ongoing monitoring and the two obligations hidden in its definition, the three thresholds in article 5 with attempts covered regardless of amount, registration and reporting through goAML as the exclusive channel, the prohibition on disclosure alongside the duty in article 5(3) to refrain from carrying out the transaction, the flagging mechanism inserted as article 5-1 by the Law of 22 July 2026, and a dedicated terrorist financing lesson on legitimate funds, NPO risk and the separate reporting and freezing duties.

Sources for this lesson

Every instrument this lesson is built from, linked to its official text

Article 5-1 was inserted into the Law of 12 November 2004 by the Law of 22 July 2026, published in Memorial A n. 412, which by the same article inserted article 74-4bis into the Law of 7 March 1980 on the organisation of the judiciary. It is the flagging mechanism running from the unit to the professional, and it is voluntary and narrow: only the professionals in article 2, paragraph 1, point 1 and point 20 may request it, which excludes undertakings for collective investment (point 4) and management companies and AIFMs (point 5). Article 5-1 requires the request to be made to the CRF through its secure IT system, the flags to be used exclusively for AML/CFT purposes and under the professional own responsibility, prohibits revealing them to the client or to third parties, and requires the professional to delete all information received under article 74-4bis(4), first subparagraph, within six months of receipt. Article 74-4bis(6) requires the CRF to meet the receiving professionals at least every six months. The statistics and typologies are in the CRF annual report 2024.

The rest of Module 4

Module 4. Monitoring, suspicion and reporting to the CRF

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