Training, documented, and beyond your employees
The training obligation restated, documented in its realisation, and expressly extending to people you do not employ.
- The video of every lesson, and the word-for-word transcript beside it
- Every claim linked to its primary source, with a source register per lesson
- An assessment for each of the 4 modules, and an end-of-course assessment
- A printable certificate carrying your name, the date and the content version
- The downloadable artefacts and one page references for this course
Expensing it? The invoice can be made out to your firm, with its VAT number and your purchase order reference. Buying for several people: seats for a team.
The narrated video runs about 29 minutes across the 12 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.
Module 3. What changes in substance
Harmonised due diligence and what a group loses when national variation closes, the training obligation documented in its realisation and extended beyond your employees, and the fund and management company overlap that a recital looks at without deciding. Lesson 3.1, harmonised due diligence, and what a group loses. Lesson 3.2, training, documented, and beyond your employees. Lesson 3.3, the fund and the management company.
Every instrument this lesson is built from, linked to its official text
Training is already obligatory and already has to be documented. Article 4(2) of the Law of 12 November 2004 requires the continuing training programmes, article 46 of CSSF Regulation 12-02 requires the programme and its realisation to be documented in writing, and article 49 requires the approved statutory auditor to verify the training measures every year. Article 12 of Regulation (EU) 2024/1624 restates the obligation and makes two things explicit: that it is duly documented, and that it extends beyond employees to agents and distributors.
- 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/
- Regulation (EU) 2024/1624, article 12, the training provision EUR-Lex, official Journal. Ongoing training programmes appropriate to function and risk, required to be duly documented, and expressly extending beyond employees to agents and distributors https://eur-lex.europa.eu/eli/reg/2024/1624/oj
Module 3. What changes in substance
- Lesson 3.1. Harmonised due diligence, and what a group loses 2:15
- Lesson 3.2. Training, documented, and beyond your employees 2:22 · this page
- Lesson 3.3. The fund and the management company 2:29
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