First quarter of 2024
Amendment of the Money Laundering Act by the MoPeG
1 January 2024
The Money Laundering Act was amended as part of the reform of partnership law (MoPeG) as of 1 January 2024. In Section 12 (2) sentence 1 GwG, the term "partnerships with legal capacity" is supplemented to include the new company form of the registered GbR (eGbR). The identity of the eGbR must be verified using an extract from the new company register (GsR), which can be viewed free of charge. In addition, the eGbR must be registered in the transparency register, as the Federal Office of Administration explains in its FAQ.
→ Act on the Modernisation of Partnership Law
Account blocking following suspicion of money laundering - decision by Frankfurt Regional Court
January 2024
Suspicious activity reports for money laundering in accordance with Section 43 AMLA pose many challenges in practice. According to the court's decision, obliged entities should not impose complete and week-long account freezes in accordance with Section 46 AMLA. According to the court, transactions on the basis of which a suspicious activity report was submitted should generally be carried out promptly after the three-day period has expired.
However, uncertainties remain: This is because this contradicts the view of BaFin, which sees the deadline as a minimum period. In addition, it should also be possible to stop transactions on the basis of which an additional deadline notification is submitted, even beyond the three-day deadline, if these give rise to suspicion. It must also be possible to hold all transactions that could result in criminal liability for reckless money laundering for longer than three days - because nothing punishable can be demanded.
→ Blog post on account blocking after suspected money laundering report
Provisional agreement between the European Parliament and the Council of the European Union on the EU money laundering package
18 January 2024
The Council and the EU Parliament have reached a provisional agreement on parts of the anti-money laundering package, which is intended to protect EU citizens and the financial system from money laundering and terrorist financing.
→ Press release of the Council of the European Union
Hearings on the seat of AMLA
30 January
The hearings of the candidate cities for the seat of the new European Anti-Money Laundering Authority (AMLA) have taken place. Among others, Germany submitted Frankfurt am Main as the future seat of the authority.
→ Consultation on the AMLA seat
Agreement on location of AMLA
22 February 2024
The Council and the EU Parliament have decided that the AMLA will be based in Frankfurt am Main. The AMLA is scheduled to begin its work in mid-2025.
→ Press release of the European Council
FIU publishes information on reporting criminal offences
March 2024
Second quarter of 2024
Europol publishes study on criminal networks
5 April 2024
Europol analyses 821 criminal networks in the EU in the study "Decoding EU's Most Threatening Criminal Networks". Germany is considered an important location, with activities such as fraud, drug and people smuggling. According to this study, many networks use legal companies for money laundering.
→ Europol report sheds light on Europe's most dangerous criminal networks
Consultation launched on draft regulation on video identification
18 April 2024
The Federal Ministry of Finance has published the draft bill for an ordinance on money laundering identification by video identification (Money Laundering Video Identification Ordinance - GwVideoIdentV).
Draft bill for a law to combat asset concealment published
23 April 2024
In April, the Federal Ministry of Finance published a draft "Act to Protect the Economic and Financial System from the Concealment and Introduction of Significant Incriminated Assets".
→ Draft bill of the Act to Combat the Concealment of Assets
Money laundering package adopted in the EU Parliament
24 April 2024
On 24 April 2024, the EU Parliament formally approved the reform package that has been under negotiation since 2021, which includes the new EU Anti-Money Laundering Regulation, an update to the EU Anti-Money Laundering Directive and a regulation establishing the EU Anti-Money Laundering Authority (AMLA).
→ EU regulations to combat money laundering
Adoption of the EU money laundering package by the Council of the European Union
31 May 2024
→ Press release of the European Council
14th EU sanctions package published
24 June 2024
The EU has adopted a 14th package of sanctions against Russia. The aim is to better prevent the circumvention of sanctions. It includes conditions for Russian LNG, a ban on Russian funding for political parties, foundations and NGOs as well as sanctions against 69 individuals and 47 organisations.
→ Press release of the Federal Government
→ Q&A of the EU Commission on the AML package
Third quarter of 2024
New FATF President elected
1 July 2024
The Mexican lawyer Elisa de Anda Madrazo took office as FATF President. She was previously Deputy President from 2020 to 2023, together with Dr Marcus Pleyer and T. Raja Kumar.
BaFin publishes a draft reform for AuAs
7 July 2024
Bafin published a draft reform for the interpretation and application notes in accordance with Section 51 (8) AMLA and invited comments. The central point of criticism here is the anticipation of provisions of the EU AML Regulation, which would result in a shortening of the transition period.
→ Draft reform for the interpretation and application notes
BMF publishes a draft for a new version of the GwGMeldV-Immobilien
2 August 2024
The Federal Ministry of Finance has published a draft revision of the GwGMeldV-Immobilien. The aim is to adapt the reporting requirements to the ban on cash payments when purchasing real estate (Section 16a GwG), which has been in force since 1 April 2023. In addition, the reporting obligations for suspicious price and payment modalities are specified in order to avoid unnecessary suspicious activity reports.
→ Draft ordinance to amend the GwGMeldV-Immobilien
BKA publishes Federal Situation Report on OC
5 September 2024
The Federal Criminal Police Office's (BKA) annually updated Federal Situation Report on Organised Crime (OC) summarises current findings on the situation and developments in Germany and reflects the results of police investigations.
→ Federal Situation Report "Organised Crime"
Fourth quarter 2024
FATF announces new methodology for adding jurisdictions to the list of jurisdictions under enhanced surveillance
17 October 2024
The aim of revising the criteria for including countries on watch lists is to reduce the pressure on the least developed countries and to focus more on countries with higher risks for the international financial system.
→ Changes to the FATF grey list criteria
Official website of the AMLA
23 October 2024
The new European money laundering supervisory authority AMLA now has an official website! There you can find out more about the authority and its future activities and explore the latest job vacancies.
Results of the FATF plenary meeting
25 October 2024
On 25 October, the Financial Action Task Force (FATF) published the results of the plenary meeting from 23 to 25 October 2024. The agenda included updating the FATF grey list.
→ Summary of the results of the FATF plenary meeting
FIU Annual Report 2023
6 November 2024
The 2023 annual report of the Financial Intelligence Unit (FIU) has been published. In the 2023 reporting year, 322,590 suspicious activity reports were submitted to the FIU.
EBA guidelines on uniform standards for the implementation of sanctions
14 November 2024
The European Banking Authority (EBA) has published two guidelines that define uniform EU standards for the first time. These concern the guidelines, procedures and controls that financial institutions should introduce to ensure the implementation of European and national sanctions
Bruna Szego nominated by the EU Parliament as President of the AMLA
26 November 2024
The European Parliament has nominated the Italian Bruna Szego for the office of President of the new authority. The AMLA thus unofficially has a new president.
Updating the BaFin AuAs
29 November 2024
The German Federal Financial Supervisory Authority (BaFin) has updated its interpretation and application notes on the Money Laundering Act. Together with the FIU, BaFin has also published guidance on suspicious activity reports.
Publication of Basel AML Index 2024
2 December 2024
The Basel AML Index is an independent ranking that assesses the risks of money laundering and terrorist financing and the ability to combat them effectively in individual countries. This year there was an important change in the methodology used. Two new indicators with data on fraud have been added.
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