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Enhanced Anti-Money Laundering (AML) reporting requirements will be enforced in Germany

Regulatory changes set for next year will enforce standardised reporting of suspicious activities, designed to enhance efficiency and expedite processes for the nation's Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) supervisory body.

Enhanced Antimoney Laundering Reporting Duties Intensify in Germany
Enhanced Antimoney Laundering Reporting Duties Intensify in Germany

Enhanced Anti-Money Laundering (AML) reporting requirements will be enforced in Germany

The Federal Financial Supervisory Authority (FIU) in Germany has announced a delay in the entry into force of the GWGMeldV from October 1, 2025, to March 1, 2026. This decision comes after considering "essential submissions" from participating associations and umbrella organizations of obligated businesses.

The GwG Reporting Ordinance (GWGMeldV), which was published on September 1, 2025, aims to homogenize suspicious activity reporting for the Central Office for Financial Transaction Investigations (FIU) in Germany. The ordinance also seeks to streamline and speed up processes for the FIU's report processing.

The delay is not the only change in the AML regulations across Europe. The Association of Foreign Banks in Germany (VAB) has expressed surprise at the ordinance being presented before the transition to the Europeanized regulatory framework. VAB also stated that the new requirements for obliged entities may only remain in effect until July 9, 2027.

Meanwhile, the UK has introduced a new law to combat economic crime. The Economic Crime and Corporate Transparency Act 2023 (ECCTA), which came into force on September 1, 2022, has introduced a failure to prevent fraud offence. Under this new law, large organizations can be criminally liable if an employee, agent, subsidiary, or associated person commits an act of fraud with the intention of benefiting the organization. To dodge prosecution in the UK, organizations will have to prove to the courts the existence of reasonable fraud prevention measures in place at the time the fraud was committed.

Moreover, the UK requires suspicious transaction reports to be submitted electronically, similar to the GWGMeldV. However, the Wolfsberg Group, an association of global financial institutions, has criticized the new regulations coming into force on October 1, 2025, aimed at standardizing suspicious transaction reporting and accelerating processing by AML/CFT supervisory authorities.

The FIU has confirmed that it will provide practical information on the interpretation and application of the regulation in the coming weeks. VAB has requested the introduction of the GwG Reporting Ordinance to be reconsidered and postponed in view of the upcoming European regulation. The ordinance, which was proposed in April 2025 and is set to come into force next year, must meet a minimum content standard by relevant entities and supervisory authorities for compliance with the reporting obligations.

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