BaFin’s new interpretation and application notes on the Anti-Money Laundering Act – a summary of the current draft consultation paper
On 9 July 2024, the German Federal Financial Supervisory Authority ("BaFin") published an updated draft of the interpretation and application notes on the Anti-Money Laundering Act ("GwG") pursuant to Section 51 (8) GwG and made them available for consultation ("Draft Consultation Paper").
In the draft consultation paper, in line with its current administrative practice, BaFin clarifies the requirements for obliged entities and adapts them to current developments in the financial sector without, however, wanting to anticipate the entry into force of the anti-money laundering package at EU level.