25 October 2023

Germany's Proposed New Approach To Money Laundering

Rahman Ravelli Solicitors


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Angelika Hellweger of financial crime specialists Rahman Ravelli outlines the changes Germany plans to make to how it tackles money laundering.
Germany Criminal Law
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Angelika Hellweger of financial crime specialists Rahman Ravelli outlines the changes Germany plans to make to how it tackles money laundering.

The German federal government has approved a draft law to create an anti-money laundering (AML) super agency and a money laundering investigation centre within it. It is now up the second chamber of the legislature, the Bundesrat, to approve this draft.1

If the bill becomes law, all essential public sector AML functions - analysis, criminal investigation and supervision – will be the responsibility of the new Federal Financial Crime Agency (FFCA).

The move is an attempt to remove problems caused by what is seen as the current fragmented nature of Germany's AML agencies. It can be viewed as a significant step in fighting money laundering in the wake of numerous scandals that have taken place; including the problems at Deutsche Bank.

The bill passing into law will lead to the creation of the Money Laundering Investigation Center (MIC) within the FFCA. MIC's sole aim will be to tackle money laundering.

The FFCA's project director Dr Marcus Pleyer said: ""It will have one objective only: fighting money laundering.

""This prevents a de-prioritisation of money laundering against other crimes - which can happen when resources must be distributed in criminal investigation agencies with a general crime fighting mandate.''

The MIC aims to investigate illicit financial flows and follow the money to the professional money launderers and the organised crime networks.

The FFCA will also create a competence centre for training and education. Germany's Federal Agency for Sanctions Enforcement will be integrated into the FFCA.

The bill is Germany's response to the issues raised by the Financial Action Task Force's (FATF's) 2022 evaluation of the nation. FATF criticised Germany for the widespread use of cash payments - even after COVID, which led to a decrease in cash transactions worldwide. German AML investigations were also said to be placing too much focus on the offence that generated the proceeds of crime rather than on the laundering of those proceeds.

The bill also includes improvements to the transparency register and the establishment of a new register of real estate transactions. The real estate register will be accessible to law enforcement and will be supplied with data from sale notices, the courts, authorities and public land registers in order for it to be a single source for real estate intelligence.


1. Fighting financial crime | Federal Government (

2. LATEST: German government approves new AML super-agency (FFCA) and establishment of 'Money Laundering Investigation Center' - AML Intelligence

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