The fund and the management company
A fund and its management company are both in scope and the work happens once. What the recital says about that, and what a recital is not.
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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
Recital 23 of Regulation (EU) 2024/1624 addresses the overlap between a collective investment undertaking and its manager. It guides interpretation and it is not an obligation, which is why this lesson stops short of saying the text requires a particular split. Article 2 of the Law of 12 November 2004 is what puts the fund and the management company in scope separately in the first place.
- Regulation (EU) 2024/1624, recital 23 EUR-Lex, official Journal. The recital addressing collective investment undertakings and their managers, and the avoidance of duplicated due diligence where both are obliged entities. A recital guides interpretation and does not itself create an obligation https://eur-lex.europa.eu/eli/reg/2024/1624/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/
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
- Lesson 3.3. The fund and the management company 2:29 · this page
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