The rows
A gap analysis is a table with four columns and about eight rows, and every one of those rows has already appeared in this course.
- 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 4. Running the gap analysis
The table itself: four columns, about eight rows, every one of them already met in this course, the sequencing rule that decides whether the plan produces anything at all, and how the analysis stays alive through the delegated acts still to come and is summarised to a board in five minutes. Lesson 4.1, the rows. Lesson 4.2, sequencing by lead time. Lesson 4.3, keeping it alive, and what to tell the board.
Every instrument this lesson is built from, linked to its official text
Every row of the table maps to a provision already cited in Modules 1 to 3: article 90 for the citation work, article 80 for the cash limit, article 52 for the beneficial ownership threshold, the customer due diligence provisions for harmonisation, article 12 for training, recital 23 for the fund and management company split, Regulation (EU) 2024/1620 and Circular CSSF 26/914 for the AMLA row, and the 2026 data collection for the templates row.
- 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
- Regulation (EU) 2024/1624, the three figures: articles 80, 52 and 90 EUR-Lex, official Journal. Article 80 is the EUR 10 000 limit on large cash payments and the power of Member States to set a lower one, article 52(1) is the 25 percent beneficial ownership threshold and article 52(2) the power of the Commission to lower it by delegated act for categories exposed to higher risk, and article 90 carries the application date of 10 July 2027 together with the later date of 10 July 2029 for professional football clubs and agents https://eur-lex.europa.eu/eli/reg/2024/1624/oj
- 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
- 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
- Regulation (EU) 2024/1620 of 31 May 2024 establishing the Authority for Anti-Money Laundering and Countering the Financing of Terrorism EUR-Lex, official Journal. The two roles kept apart: direct supervision of a small number of selected entities, with the eligibility criteria in article 12 and the selection in article 13, and the standard setting, technical standards, guidelines and coordination of national supervisors that reach every obliged entity https://eur-lex.europa.eu/eli/reg/2024/1620/oj
- Circular CSSF 26/914 of 25 June 2026 CSSF circular. Identification of the obliged entities eligible for direct supervision by the AMLA, against the eligibility criteria in article 12(1) of Regulation (EU) 2024/1620. Eligibility for consideration, which is a wider set than selection https://www.cssf.lu/en/Document/circular-cssf-26-914/
Module 4. Running the gap analysis
- Lesson 4.1. The rows 2:13 · this page
- Lesson 4.2. Sequencing by lead time 2:22
- Lesson 4.3. Keeping it alive, and what to tell the board 2:58
Open this lesson
Access to The 2027 AML package: a gap analysis for your entity opens the video, the word-for-word transcript, the module assessments and the certificates. If you already have access, sign in and this page becomes the lesson.
Or watch lesson 1-1 of this course free, with no account: The 2027 AML package: a gap analysis for your entity, the free sample.