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Lesson 2 of 3 · Module 3

Training, documented, and beyond your employees

The training obligation restated, documented in its realisation, and expressly extending to people you do not employ.

2:22 Module 3. What changes in substance The 2027 AML package: a gap analysis for your entity
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What Module 3 covers

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.

Sources for this lesson

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
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Module 3. What changes in substance

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