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ARTICLE · 03 NOVEMBER 2026

Germany’s New Money Laundering Combating Act

A&O Shearman
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Germany's Federal Ministry of Finance has published a draft bill implementing the EU Anti-Money Laundering Package, introducing sweeping changes to the country's AML framework through a new Money Laundering Combating Act. The legislation expands the scope of obliged entities, modernizes automated account access systems with EU-wide connectivity, and restructures supervisory mechanisms while maintaining direct application of EU regulations for most substantive obligations.

GermanyGovernment, Public Sector
Alexander Behrens
Alexander Behrens
Martina Stegmaier
Martina Stegmaier
Niklas Germayer
Niklas Germayer
Oliver Marks
Oliver Marks
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On October 28, 2026, the Federal Ministry of Finance (Bundesfinanzministerium—BMF) published the draft bill (Referentenentwurf) (the Draft Bill) implementing the so-called EU Anti-Money Laundering Package consisting of the Sixth Anti-Money Laundering Directive (AMLD6), the Anti-Money Laundering Regulation (AMLR), the AMLA Regulation (AMLAR), as well as the Directive amending the Directive (EU) 2024/1654 (Financial Information Directive). 

The Draft Bill is a so-called umbrella act (Artikelgesetz) which amends a number of laws, repeals the current German Anti-Money Laundering Act (Geldwäschegesetz—GwG) and replaces it with a new core statute, the Money Laundering Combating Act (Geldwäschebekämpfungsgesetz—GwBG; in its draft form GwBG-E). 

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