Sequencing by lead time
Sequence by lead time rather than by importance, because the most important row is often the one that cannot start yet.
- 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
Sequencing does not rest on any new instrument. The three groups are read off the same provisions: the work available today is the citation work under article 90, the training population under article 12 and the documented split under recital 23; the quick work is the AMLA eligibility sentence under Regulation (EU) 2024/1620 and Circular CSSF 26/914 and the threshold parameter under article 52; and the work that cannot start yet is what waits on a delegated act, on technical standards, or on the Luxembourg transposition of Directive (EU) 2024/1640.
- 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) 2024/1620 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
- 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/
Module 4. Running the gap analysis
- Lesson 4.1. The rows 2:13
- Lesson 4.2. Sequencing by lead time 2:22 · this page
- Lesson 4.3. Keeping it alive, and what to tell the board 2:58
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