Germany's Finance Ministry has prepared a draft law to implement the EU's 2024 anti-money laundering package without adding national requirements beyond the EU framework. The proposal is under internal government consultation and complements the government's action plan against tax and financial crime.
Key aspects include:
- New legal framework: The existing 2017 Money Laundering Act would be repealed on 10 July 2027 and replaced by a new law combating money laundering and terrorist financing. Amendments to the Banking Act and Federal Criminal Police Office Act are also planned.
- Coordinated supervision: A central coordination unit for anti-money laundering supervision would be established at BaFin.
- Ownership transparency: The proposal seeks greater transparency about the beneficial owners behind companies, organisations and foundations.
- Property and banking information: A central access point for real estate information is planned for July 2029, particularly to support law enforcement. Bank account retrieval systems would also become better interconnected across Europe.
- Business obligations and cash limits: The underlying EU package sets out which businesses must perform customer identity checks and report suspicious activity. It also introduces a €10,000 ceiling on commercial cash payments, excluding transactions between private individuals.
- Implementation costs: Additional federal expenditure with 32 additional full-time positions is planned at BaFin.
The proposal has not yet been enacted. Cabinet approval is reportedly expected before the end of 2026.












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