Electronic notification of the money laundering reporting officer: New requirements from BaFin

With the latest update to BaFin’s Interpretative and Application Guidance on the German Anti-Money Laundering Act (as of July 2025), the reporting process for appointing a money laundering reporting officer has been fundamentally modernised: instead of submitting the notification by post or email, it must now be completed entirely electronically via the Reporting and Publication Portal (MVP Portal).

According to Section 3.2.1 of the updated guidance (as of July 2025), both the appointment and removal of the designated money laundering reporting officer and their deputy must be reported to BaFin in good time before the start or end of their role. As a rule, “in good time” means that the notification should be submitted at least two weeks before the appointment or resignation takes effect. BaFin also reserves the right to request proof of qualifications (e.g. CVs, training certificates) and conduct reliability checks (e.g. criminal record extracts from the Federal Central Register).

Accessing the MVP portal in a few steps

To ensure smooth electronic registration, you must use BaFin’s MVP Portal. Access is via the BaFin website (www.bafin.de) under Service → MVP-Portal. After a one-time self-registration using your business email address (as the contact person of an obliged entity), you will receive a username and password. Then, within the portal, you apply for access to the relevant procedure: “Anti-Money Laundering and Counter-Terrorism Financing”. To do so, go to “Apply for specialist procedure”, select the appropriate entry, and indicate whether you are acting as a direct notifier (on behalf of your company) or as a third-party notifier. Once BaFin accepts your application, you will be notified by email. The status “accepted” in the portal indicates that you can now submit notifications.

Submitting appointments and removals digitally

To file the actual appointment, navigate to the form “Appointment/Change/Removal of the MLRO” under “Submit notification” in the specialist procedure section. Important: When appointing a new officer, you must first submit a removal notification for the current MLRO, followed by the appointment notification for the new one. After submitting the online form, you will immediately see a confirmation message. A PDF version of this confirmation can be generated and saved — useful as evidence for auditors or the FIU. Under “View log”, you can check the status of your submission. Only once the status shows “notification accepted” is the submission considered formally complete. A substantive review will take place separately. If questions arise, BaFin will contact you directly.

This electronic solution is designed to make the appointment process for MLROs more transparent, verifiable, and efficient — allowing you to meet all formal BaFin requirements digitally.