According to section 3.2.1 of the updated guidance, both the appointment and the dismissal of the person appointed to perform this task and their deputy must be reported to BaFin in good time before taking up or resigning from the position. As a rule, notification is deemed to have been made in good time if it is submitted at least two weeks before taking up or resigning from the position. In addition, BaFin reserves the right to subsequently request proof of qualifications (e.g. professional background or training certificates) and background checks (e.g. information from the Federal Central Criminal Register).
Access to the MVP portal in just a few steps
To ensure smooth electronic registration, you must use the MVP portal. The way there is via the BaFin website (www.bafin.de) and there under Service → MVP portal. After a one-off self-registration with your business e-mail address as the contact person of an obliged entity, you will be shown your user name and password. You then apply for authorisation for the specialist procedure "Prevention of money laundering and terrorist financing" in the portal. To do this, select the relevant entry under "Apply for specialised procedure" and specify whether you wish to appear as a direct reporter (name of your company) or as a third-party reporter. As soon as your application has been accepted by BaFin, you will receive an e-mail notification; the "accepted" status in the portal indicates that you can now submit reports.
Submit appointment and cancellation digitally
For the actual appointment, navigate in the specialised procedure under "Submit notification" to the form "Appointment/change/disengagement of anti-money laundering officers". Important: In the case of new appointments, you must first submit a notification of dismissal of the previous anti-money laundering officer and then the notification of appointment of the new anti-money laundering officer. After submitting the online form, a confirmation message will appear immediately. A PDF of this confirmation can be generated and saved locally with a click. This can serve as practical proof for auditors or the Financial Intelligence Unit. In the "View log" menu, you can check whether the status "Message accepted" is displayed; only then is the transmission formally completed. The content will be checked separately and BaFin will contact you directly if there are any queries.
This electronic solution is designed to make the appointment of an anti-money laundering officer transparent, verifiable and efficient. A process with which you can fulfil all formal BaFin requirements digitally.
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