These transactions deliberately circumvent legal requirements, for example by concealing the economic or country-specific background - a serious problem for obligated parties.
Examples of avoidance transactions according to BaFin
Letterbox companies: Fictitious companies that conceal the true beneficial owner.
Chains of intermediaries: Numerous middlemen at home and abroad serve to disguise the true business intentions.
Conspicuous transaction patterns: These can include round transaction amounts or generic purposes.
What does this mean for obligated parties?
Increased due diligence obligations must be applied if there are indications of circumvention transactions (Section 15 AMLA). If there are doubts about the identity of customers, evidence or beneficial owners, the submission of a suspicious activity report in accordance with Section 43 GwG must be examined. If individual due diligence obligations cannot be fulfilled against this background, the business relationship must be terminated or not established (Section 15 para. 9 in conjunction with Section 10 para. 9 GwG).
Above all, transparency and control are important; these are the key to prevention.
You can find the BaFin supervisory notice here here.
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