If you fall under the following groups of obliged entities under the Money Laundering Act, you must appoint a (group) money laundering officer at management level and a deputy. The appointment of the (group) anti-money laundering officer and his/her deputy must be notified to the supervisory authority in advance.

Notification is possible for the following obliged entity groups here:

• Financial companies with activities pursuant to Section 1 (24) GwG
• Insurance intermediaries
• Non-chambered legal advisors and registered persons pursuant to Section 10 of the Legal Services Act
• Service providers for companies and trust assets or trustees
• Real estate agents
• Organizers and brokers of games of chance (bookmakers, organizers and brokers of sports betting, casinos, horse betting on the Internet, lotteries on the Internet)
• Goods dealers, art brokers and art stockists

In some cases, the obligations under the AMLA only apply if certain activities are carried out or threshold values are reached - you can find more detailed information on this under further information.

• (Group) money laundering officers are responsible for compliance with money laundering regulations. They are directly subordinate to the management.
• The responsibility of the management level continues to exist.
• The most important tasks of the money laundering officers include the following
  • they are the point of contact for the law enforcement authorities, the Financial Intelligence Unit (FIU) and for the supervisory authority, which check compliance with due diligence obligations.
  • They are responsible for carrying out and updating the risk analysis, designing internal measures and monitoring compliance with due diligence obligations within the company.
  • they submit suspicious activity reports to the Financial Intelligence Unit (FIU) or respond to requests for information from these bodies.
• The parent company must appoint a Group Money Laundering Officer and, if necessary, a deputy, who are responsible for drawing up a uniform Group-wide strategy for the prevention of money laundering and terrorist financing and for coordinating and monitoring its implementation.
• They fulfill the following tasks:
  • Group Money Laundering Officers must create binding cross-company procedures for implementing the obligations under money laundering law in the branches, subsidiaries and group-affiliated companies in Germany and abroad that are subject to the group and ensure that these are observed. They have the authority to do this by inspecting audit reports or conducting their own spot checks. The designated member of the parent company's management must be informed of the results regularly and if necessary.
  • If necessary, they must also take cross-company (control) measures.
  • Group Money Laundering Officers do not replace the Money Laundering Officers that may be required at the group companies.