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ARTICLE · 04 DECEMBER 2024

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New AML Guidance From BaFin And FIU

Hengeler Mueller
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On 29 November 2024, Germany's Federal Financial Services Supervisory ­Authority ("BaFin") and Financial Intelligence Unit ("FIU") released two important publications on obligations under AML law.

GermanyGovernment, Public Sector
Christian Schmies
Christian Schmies
Gerrit Tönningsen
Gerrit Tönningsen
Charlotte Van Kampen
Charlotte Van Kampen
Marvin Geisler
Marvin Geisler

A (New) "To Do" List for Obliged Entities

On 29 November 2024, Germany's Federal Financial Services Supervisory Authority ("BaFin") and Financial Intelligence Unit ("FIU") released two important publications on obligations under AML law:

  1. an update to BaFin's Interpretation and Application Guidance on the German Anti-money Laundering Act (Auslegungs- und Anwendungshinweise zum Geldwäschegesetz – "AuA 2024")1 and
  2. new interpretative guidance jointly written by BaFin and the FIU on the concepts of "Unverzüglichkeit" (without undue delay) and "Vollständigkeit" (completeness) as they relate to suspicious activity reports ("Joint SAR Guidance" or "Guidance").2

All obliged entities subject to BaFin supervision must be compliant with the AuA 2024 as of 1 February 2025, meaning that these entities need to determine whether and how they are not in compliance with the AuA 2024 and implement the necessary adjustments in a rather short timeframe. The joint SAR

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