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Lesson 1 of 3 · Module 1

From a directive to a regulation

What changes when an obligation stops arriving through a Luxembourg law and starts applying directly, and the citation work that follows from it.

2:32 Open to everyone Module 1. What actually changes
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On the tenth of July 2027, Regulation 2024/1624 applies, and most of what you do today does not disappear. It gets restated in a European instrument that applies directly, without a Luxembourg law in between. Start with why that matters, because it is not a technicality. A directive tells member states what result to achieve and leaves them to legislate. That is why the framework you work in is Luxembourgish: a law of 2004, a grand ducal regulation, a CSSF regulation. Twenty seven member states each did that, and they did it differently.

A regulation applies as it is written, in every member state, at the same moment. There is no transposition, and no national variation to hide behind. Now the consequence nobody budgets for. Every internal procedure you own cites Luxembourg provisions. Your customer due diligence policy cites article 3.

Your appointment paperwork cites articles 40 to 45 of the CSSF regulation. Your training programme cites article 46. After July 2027, a reader following those citations arrives at provisions that no longer carry the obligation. Nobody is going to do that renumbering for you, and the volume of it is the single most underestimated part of this transition. It is also the part you can start today, which is why it opens this course.

One caution before we go further, and it runs through the whole module. The directive is not gone. Directive 2024/1640 sits alongside the regulation, and it is transposed nationally, on its own timetable. So the answer to, is it all European now, is no. Some of it is directly applicable, some of it arrives through Luxembourg law, and knowing which is which is the same habit this framework has always demanded.

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Sources for this lesson

Every instrument cited above, linked to its official text

Regulation (EU) 2024/1624 is the directly applicable instrument and Directive (EU) 2024/1640 is the half that still arrives through national law, which is why the answer to whether it is all European now is no. The citations this lesson is about are the ones in your own documents: article 3 and article 4 of the Law of 12 November 2004, and articles 40 to 46 of CSSF Regulation 12-02.

  • Regulation (EU) 2024/1624 of 31 May 2024, the single AML rulebook EUR-Lex, official Journal. The directly applicable half of the package. Article 90 carries the application date of 10 July 2027, and it is the instrument that restates the obligations you already carry https://eur-lex.europa.eu/eli/reg/2024/1624/oj
  • Directive (EU) 2024/1640 of 31 May 2024 on the mechanisms to be put in place by Member States EUR-Lex, official Journal. The half of the package that is not directly applicable: the supervisory and financial intelligence unit architecture, the registers and the national mechanisms, all of which still arrive through Luxembourg law on their own timetable https://eur-lex.europa.eu/eli/dir/2024/1640/oj
  • Law of 12 November 2004 on the fight against money laundering and terrorist financing Coordinated text published by the CSSF. Article 2 is scope, which is what puts a fund and its management company in scope separately, article 3 is due diligence and article 4, in particular article 4(2), is internal organisation and continuing training. These are the provisions your current procedures cite https://www.cssf.lu/en/Document/law-of-12-november-2004/
  • CSSF Regulation No 12-02 of 14 December 2012 Coordinated version published by the CSSF. Articles 40 to 45 are the appointment and notification of the RC and the RR, article 46 requires the training programme and its realisation to be documented in writing, and article 49 is the annual verification of the training measures by the approved statutory auditor. These are the article numbers your paperwork cites today https://www.cssf.lu/en/Document/cssf-regulation-n12-02-2/
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Content written from the primary sources. Each instrument carries its own verification date in the source register. Content version: 23 August 2026

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