BaFin has identified the following points in its special audits:
1. money laundering officers often take on other tasks (e.g. securities compliance or the legal department).
2. money laundering officers cannot adequately fulfil their duties under money laundering law (e.g. work backlogs for hits in transaction monitoring or screening; suspicious cases processed too late / submitted too late).
3. not heeding warnings from money laundering officers in favour of potential revenue opportunities.
4. the regulatory framework is complex and its implementation is very time-consuming.
5 Effective money laundering prevention is very resource-intensive.
What you should consider
- Money laundering officers need a strong position in the company.
- Sufficient human, material and financial resources are needed to prevent money laundering.
BaFin emphasises - These are tasks of the management!