ACAMS Today, Sept-Nov 2023 September-November 2023

Sara Seddon Kilbinger , “ Germany considered ‘ paradise ’ for money laundering ,” Refire , October 26 , 2022 , https :// www . refire-online . com / investment / germany-considered- % E2 % 80 % 98paradise % E2 % 80 % 99-for-money-laundering /

Ibid . access to the data it needed ,” he stated in an interview with DW , a German international broadcaster . “ And even today it doesn ’ t have full access .” 18

Germany houses 300 regional bodies across 16 states tasked to monitor money laundering , which FATF criticized for being fragmented and inconsistent . 19 FATF also raised eyebrows when it found that in 2020 , the country prosecuted 1,000 individuals for money laundering despite having launched 37,000 inquiries . 20

Is the BBF the answer ?

The BBF has an arduous task when it will become operational in 2024 , but certain details seem promising .

The Ministry of Finance plans to integrate the national FIU into the new authority and have a staff of around 2,000 employees . Moreover , the BBF plans to train additional qualified financial investigators , which could ease the burden of the FIU and expedite the sifting of SARs . 21

Lindner has also acknowledged the issue of the disparate antimoney laundering ( AML ) bodies in Germany ’ s various states and has pledged to centralize control and promote the digitization and joining of registers . 22

Criticism toward the novel initiative has already begun to surface . Konrad Duffy , a financial crime specialist at Finanzwende , a nonprofit that promotes transparency in the financial sector , believes that “ There ’ s more to a paradigm shift in fighting money laundering than creating a new agency .” In an interview with DW , he states that “ Apart from powerful authorities , we need more transparency with the value of fortunes , a quick implementation of the promised ban on buying real estate with cash and better possibilities for confiscating dirty money .” 23

Conclusion

The problem of cash persists and is one that the BBF cannot solve . The German government will need to impose limits and bans on its use , thus blocking the influx of ill-gotten funds into the country and making it easier for FIs and authorities to monitor their flow . Great transparency and communication on all levels will also be needed for the BBF to successfully carry out its mission .

Germany ’ s new AML authority has steep challenges on the horizon , but its creation has the potential to pave the way for a stronger defense against financial crime .

Stefano Siggia , CAMS , senior consultant , Pideeco , Belgium , stefano @ pideeco . be ,

“ Germany to set up new body to combat money laundering ,” Reuters , July 24 , 2023 , https :// www . reuters . com / world / europe / germany-set-up-new-body-combatmoney-laundering-2023-07-24 /

Ben Knight , “ Why the mafia loves Germany ,” DW , June 5 , 2023 , https :// www . dw . com / en / why-the-mafia-loves-germany / a-65524610

Nicole Oubre , “ The Effects of the Italian Mafia in Germany ,” Willy Brandt School of Public Policy Blog , January 17 , 2020 , https :// thebulletin . brandtschool . de / the-effects-of-theitalian-mafia-in-germany

Ruth Schneider , “ Who owns Berlin ?” Exberliner , May 29 , 2020 , https :// www . exberliner . com / politics / who-owns-berlin /

Ben Knight , “ Why the mafia loves Germany ,” DW , June 5 , 2023 , https :// www . dw . com / en / why-the-mafia-loves-germany / a-65524610

Ruth Schneider , “ Who owns Berlin ?” Exberliner , May 29 , 2020 , https :// www . exberliner . com / politics / who-owns-berlin /

Ibid .

Franziska Hahn , Dr . Martin Bartlik , Dr . Martin Knaup , et al . “ German Transparency Register – What you need to know about the obligation to register ( not only as a property owner ),” TaylorWessing , April 3 , 2023 , https :// www . taylorwessing . com / en / insights-and-events / insights / 2023 / 03 / german-transparency-register

Maria Maggiore and Laure Brillaud , “ Dark screen for transparency : public access to ultimate ownership data abolished by European Court of Justice ,” Investigate Europe , November 30 , 2022 , https :// www . investigate-europe . eu / en / posts / public-access-to-ubo-abolished-by-european-court-of-justice

Daniel Travers , Marcel Michaelis and Janina Heinz , “ Germany raids its own financial intelligence authority over backlog of suspicious activity reports ,” Freshfields Bruckhaus Deringer , July 17 , 2020 , https :// riskandcompliance . freshfields . com / post / 102gbph / germany-raids-its-own-financial-intelligence-authority-over-backlog-of-suspicious

“ Germany to set up new body to combat money laundering ,” Reuters , July 24 , 2023 , https :// www . reuters . com / world / europe / germany-set-up-new-body-combatmoney-laundering-2023-07-24 /

Ben Knight , “ Why the mafia loves Germany ,” DW , 5 June 5 , 2023 , https :// www . dw . com / en / why-the-mafia-loves-germany / a-65524610

Inci Sayki , “ Experts : Germany Must do More to Combat Money Laundering ,” OCCRP , August 30 , 2022 , https :// www . occrp . org / en / daily / 16707-experts-germany-must-do-more-tocombat-money-laundering

Kyle Brasseur , “ Reports : Germany targeting 2024 for new AML agency ,” Compliance Week , July 27 , 2023 , https :// www . complianceweek . com / regulatory-enforcement / reportsgermany-targeting-2024-for-new-aml-agency / 33361 . article # toggle

Ben Knight , “ Germany announces crackdown on money laundering ,” DW , August 26 , 2022 , https :// www . dw . com / en / germany-announces-crackdown-on-moneylaundering / a-62941625 ACAMS Today September – November 2023 111

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