BaFin AML Guide Consultation

On Dec. 11, 2018 GE BaFin published the finalized version of the AML guidance.

  • Interpretation and application instructions to the money laundering act (GwG).
  • Implementing customer due diligence, internal safeguards, risk-based approach.
  • Legal innovations, e.g. the concept of fictitious beneficial owner, are explained.
  • Obligations in connection with identification of the person appearing are clarified.
  • Interpretative notes take into account developments in markets and regulations.