Germany

New Documents

G7 Finance Ministers, Central Bank Governors Issue Statement on Digital Payments, Ransomware

The finance ministers and central bank governors of the G7 member countries issued a joint statement on the widespread adoption of digital payments, highlighting risks related to financial stability, consumer protection, taxation, cybersecurity, money laundering and terrorist financing.

October 13, 2020

Germany, France to Explore Sanctions Against Persons Involved in Navalny Poisoning

Germany’s Foreign Minister Heiko Maas and French Minister of Europe and Foreign Affairs Jean-Yves Le Drian issued a joint statement condemning the poisoning of Alexi Navalny in Russian territory and pledging to explore sanctions in response.

October 8, 2020

BaFin Publishes Perspectives Report on Cybersecurity in Financial Sector

August 11, 2020

International Police Operation Arrests 46 Members of Sicilian Mafia Cosa Nostra

July 2, 2020

BaFin Issues Guidance on Crypto Business Requirements, Including AML Rules

May 11, 2020

News

Midweek Roundup: Deutsche Bank Hit with German AML Fine, Germany’s FIU Discovers More Wirecard-linked STRs, and More

Mexican FIU freezes hundreds of bank accounts, FinCEN details red flags of unemployment insurance fraud, and more, in the midweek roundup.

October 14, 2020

With STRs, Quantity Over Quality Wins the Day in Most European Nations

STRs dropped significantly last year in Luxembourg, Belgium and the Netherlands after authorities began emphasizing quality over quantity of reporting and eliminated certain numerical thresholds for filing.

October 13, 2020

Midweek Roundup: BNP Paribas Hit with Epstein Subpoena, Swiss Accuse Bank of AML Breaches, and More

October 7, 2020

Weekly Roundup: US Officials Target Ransomware Payments, Pennsylvania Bank Must Bolster AML Program, and More

October 2, 2020

In Germany, Investigation Looms for Wirecard and AML Supervisors Alike

September 11, 2020

Enforcement Actions

Germany Orders Deutsche Bank AG to Improve AML Controls

Germany’s Federal Financial Supervisory Authority (BaFin) ordered Deutsche Bank AG to adhere to the customer due diligence obligations stipulated in the German Money Laundering Act.

September 25, 2018

Key Documents

Germany Revises Main AML Legislation

June 27, 2013

Germany Releases Banking Act

June 25, 2009

Germany Issues Risk Assessment Guidelines

March 24, 2005

Important Facts

  • The U.S. State Department labels Germany as a jurisdiction of primary concern. Although not an offshore financial center, Germany is one of the largest financial centers in Europe. Germany is a member of the Eurozone, which makes it attractive to organized criminals and tax evaders. Indicators suggest that the jurisdiction is susceptible to money laundering and terrorist financing because of its large economy, advanced financial institutions and strong international connections. Although not a major drug-producing country, Germany continues to be a consumer and a major transit hub for narcotics. There is little data on the scale of activity, but Germany is estimated to have a large informal financial sector; informal value transfer systems such as hawala are used by immigrant populations accustomed to such systems in their home countries. Trends in money laundering include a decrease in cases involving financial agents. Cybercrime continues to challenge law enforcement and there has been an increase in cases of tax evasion, transnational collusive agreements and manipulations, and corruption and money laundering involving global financial institutions and corporations. Bulk cash smuggling by organized criminals also remains prevalent in Germany.
  • KYC Covered Entities: Banks, financial services, payment, and e-money institutions and their agents; financial enterprises; insurance companies and intermediaries; investment companies; lawyers, legal advisers, auditors, chartered accountants, tax advisers, and tax agents; trust and company service providers; real estate agents; casinos; and persons trading in goods
  • STR Covered Entities: Banks, financial services, payment, and e-money institutions and their agents; financial enterprises; insurance companies and intermediaries; investment companies; lawyers, legal advisers, auditors, chartered accountants, tax advisers, and tax agents; trust and company service providers; real estate agents; casinos; and persons trading in goods
  • Enhanced Due Diligence Procedures for PEPs: Foreign: Yes; Domestic: No
  • Money Laundering Criminal Prosecutions/Convictions: Prosecutions: 992 (2013); Convictions: 882 (2013)
-Source: 2016 International Narcotics Control Strategy Report (INCSR)

Rankings

FATF i

Technical Effectiveness
Compliant : 5 High :
Largely Compliant : 24 Substantial :
Partially Compliant : 15 Moderate :
Non-Compliant : 5 Low :

BASEL i

Rank : 107/141
Score : 4.42/10

TRANSPARENCY INTERNATIONAL i

Rank : 9/180
Score : 80/100

Tax Justice Network i

Rank : 14/133
Score : 52/100