First Quarter 2024
Amendment of the German Anti-Money Laundering Act (GwG) through the MoPeG
1 January 2024
The German Anti-Money Laundering Act (GwG) was amended as part of the reform of partnership law (MoPeG) on 1 January 2024. Section 12 (2) sentence 1 GwG now includes “legal partnerships” to reflect the new legal form of the registered GbR (eGbR). The identity of the eGbR must be verified via an extract from the new Company Register (Gesellschaftsregister – GsR), which is publicly accessible free of charge. Additionally, the eGbR must be registered in the Transparency Register, as stated in the FAQs of the Federal Office of Administration.
→ Law on the Modernisation of Partnership Law (MoPeG)
Account blocking following suspicious transaction report – ruling of the LG Frankfurt
January 2024
Suspicious transaction reports under Section 43 GwG pose many challenges in practice. According to a court decision, obligated entities should not impose complete or prolonged account freezes under Section 46 GwG. The court held that transactions reported as suspicious should, in general, be processed promptly once the three-day holding period expires.
However, uncertainty remains: this contradicts BaFin’s view that the three-day period is a minimum. Furthermore, transactions related to a follow-up report or posing a clear money laundering risk may still justify a longer freeze.
→ Blog post on account blocking after STR
Provisional agreement between the European Parliament and the Council on the EU AML package
18 January 2024
The Council and Parliament reached a provisional agreement on parts of the AML package, which aims to protect EU citizens and the financial system from money laundering and terrorist financing.
Hearings on the seat of AMLA
30 January
Hearings for the candidate cities for the new EU Anti-Money Laundering Authority (AMLA) took place, including Germany’s bid to host the authority in Frankfurt am Main.
Final decision: AMLA to be located in Frankfurt
22 February 2024
The Council and Parliament decided that the AMLA will be headquartered in Frankfurt. AMLA is expected to become operational in mid-2025.
→ European Council press release
FIU publishes guidance on reporting criminal complaints
March 2024
Second Quarter 2024
Europol publishes study on criminal networks
5 April 2024
Europol’s study “Decoding EU’s Most Threatening Criminal Networks” analyzes 821 criminal networks operating in the EU. Germany is identified as a key location, with criminal activities including fraud, drug trafficking, and human smuggling. According to the study, many networks launder money through legal businesses.
→ Europol report highlights Europe’s most dangerous criminal networks
Consultation launched on draft regulation for video identification
18 April 2024
The German Federal Ministry of Finance has published a draft regulation for anti-money laundering identification via video (Money Laundering Video Identification Regulation – GwVideoIdentV).
→ Draft Regulation on Video Identification (GwVideoIdentV)
Draft law to combat asset concealment published
23 April 2024
The German Ministry of Finance released a draft for the Law to Protect the Economic and Financial System from the Concealment and Introduction of Significant Incriminated Assets (Vermögensverschleierungsbekämpfungsgesetz).
→ Draft law on asset concealment
EU Parliament passes AML package
24 April 2024
On 24 April 2024, the EU Parliament formally approved the long-negotiated AML reform package, including the new EU Anti-Money Laundering Regulation (EU-AML-VO), updates to the AML Directive, and the regulation establishing the AMLA.
→ EU rules on fighting money laundering
Council of the EU adopts AML package
31 May 2024
→ European Council press release
14th EU sanctions package adopted
24 June 2024
The EU adopted its 14th sanctions package against Russia, focusing on better enforcement and prevention of sanctions circumvention. Measures include restrictions on Russian LNG, a ban on Russian funding for political parties, foundations, and NGOs, and sanctions against 69 individuals and 47 entities.
→ German Federal Government press release
→ EU Commission Q&A on the AML package
Third Quarter 2024
New FATF president elected
1 July 2024
Mexican lawyer Elisa de Anda Madrazo assumed the role of FATF President. She previously served as Vice-President from 2020 to 2023, alongside Dr. Marcus Pleyer and T. Raja Kumar.
BaFin publishes draft for revised guidance (AuA)
7 July 2024
BaFin published a draft of its revised interpretation and application notes pursuant to § 51 (8) of the German AML Act (GwG), inviting stakeholders to submit comments. A central point of criticism is that the draft preempts regulations from the EU-AML Regulation, effectively shortening the transitional period.
German Ministry of Finance releases draft of revised real estate AML reporting regulation
2 August 2024
The Federal Ministry of Finance released a draft for a new version of the AML Reporting Regulation for Real Estate (GwGMeldV-Immobilien). The aim is to align reporting obligations with the cash payment ban in real estate transactions (§ 16a GwG) that has been in effect since 1 April 2023. Reporting duties related to suspicious pricing and payment methods are also clarified to avoid unnecessary suspicion reports.
→ Draft regulation GwGMeldV-Immobilien
Federal Criminal Police Office (BKA) publishes national report on organized crime
5 September 2024
The annually updated national situation report “Organized Crime” by the German Federal Criminal Police Office (BKA) summarizes current insights into the state and development of organized crime in Germany, based on police investigations.
→ Organized Crime situation report
Fourth Quarter 2024
FATF announces new methodology for listing jurisdictions under increased monitoring
17 October 2024
The aim of revising the criteria for placing countries on watchlists is to reduce pressure on the least developed countries and to focus more on jurisdictions that pose higher risks to the international financial system.
→ Changes to FATF grey list criteria
Official website of AMLA
23 October 2024
The new European Anti-Money Laundering Authority (AMLA) has launched its official website! There you can learn more about the authority’s future tasks and browse current job postings.
FATF plenary meeting results
25 October 2024
On 25 October, the Financial Action Task Force (FATF) published the outcomes of its plenary meeting held from 23–25 October 2024. One key agenda item was the update of the FATF grey list.
→ Summary of FATF plenary results
FIU Annual Report 2023
6 November 2024
The 2023 annual report of Germany’s Financial Intelligence Unit (FIU) has been published. A total of 322,590 suspicious activity reports (SARs) were submitted to the FIU during the reporting year.
EBA guidelines on harmonised standards for sanctions implementation
14 November 2024
The European Banking Authority (EBA) published two new guidelines that, for the first time, define uniform EU-wide standards. These concern the policies, procedures, and controls that financial institutions must implement to ensure the enforcement of EU and national sanctions.
Bruna Szego nominated as AMLA president by the European Parliament
26 November 2024
The European Parliament has nominated Italian candidate Bruna Szego to lead the new anti-money laundering authority. AMLA now has an unofficial president-elect.
BaFin updates its interpretation and application guidance (AuA)
29 November 2024
The Federal Financial Supervisory Authority (BaFin) has updated its guidance on the German AML Act. In addition, BaFin and the FIU jointly published new orientation guidelines for submitting suspicious activity reports.
Basel AML Index 2024 published
2 December 2024
The Basel AML Index is an independent ranking that evaluates countries based on their risk of money laundering and terrorist financing, as well as their ability to effectively counter those risks. This year, the methodology was updated to include two new indicators based on fraud data.
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