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Anti-Money Laundering Act: BaFin updates interpretation and application notes


The German Federal Financial Supervisory Authority (BaFin) published its updated Interpretative and Procedural Guidance on the Anti-Money Laundering Act (AuA AT) on 29 November 2024, which will take effect on 1 February 2025 and contain detailed information on the application of legal requirements such as customer identification, transaction monitoring, internal security measures and reporting obligations.



The update takes into account current legislative initiatives such as the Future Financing Act (Zukunftsfinanzierungsgesetz) and the Whistleblower Protection Act (Hinweisgeberschutzgesetz) while also preparing for the EU Anti-Money Laundering Regulation coming into force in 2027. Among other things, the new requirements define risk-oriented time intervals for customer checks ranging from one year for increased risk to five years for normal risk and introduce more precise requirements for handling suspicious activity reports to the Financial Intelligence Unit (FIU).





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