Germany's financial regulator BaFin has issued new supervisory guidance on virtual IBANs, addressing concerns about transparency in payment flows and beneficial ownership while affirming that vIBANs remain legitimate payment infrastructure. The communication requires firms to demonstrate that their governance, customer transparency and monitoring arrangements have kept pace with technological innovation, particularly in relation to anti-money laundering and counter-terrorist financing controls.
GermanyFinance and Banking
EU RegCORE Client Alert | German Regulatory Developments
QuickTake
On 27 July 2026, the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht – Bafin) published Supervisory Communication (“Aufsichtsmitteilung”) 06/20261 together with an accompanying interview explaining its supervisory concerns regarding the use of virtual IBANs (vIBANs) in connection with underground banking and money laundering.2 The supervisory communication applies immediately and will remain in force until the EU Anti-Money Laundering Regulation (AMLR) becomes applicable on 10 July 2027.
The publication is significant not because Bafin questions the legitimacy of vIBANs themselves, but because it recognises that certain complex implementation models may create opacity over the identity of end customers, beneficial ownership and payment flows. Bafin’s message is nuanced: vIBANs are legitimate payment infrastructure that underpin many modern financial services business
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