Anti-Money-Laundering Officer
Risk analysis, KYC/KYB, suspicious-activity reporting to FIU. § 7 GwG appointment documented, reporting line clean, BaFin-inspection ready.
§ 7 GwG · FIU reporting
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What is an AML Officer in Germany?
An anti money laundering officer Germany is the statutory function under Section 7 of the German Money Laundering Act (GwG) that obliged entities must designate at management level. The officer is the first line of defence and reports directly to the management board. The catalogue of obliged entities in Section 2 GwG includes banks, payment institutions, insurance undertakings with life or accident products, asset managers, real estate agents above the 10,000 euros threshold, notaries, tax advisors, auditors, lawyers in certain mandates, dealers in goods accepting cash payments of 10,000 euros or more, art intermediaries and crypto-asset service providers under MiCAR. The officer is responsible for the risk analysis under Section 5 GwG, the internal procedures and controls under Section 6 GwG, the customer due diligence under Sections 10 to 17 GwG, the ongoing monitoring of transactions and the suspicious activity reports to the Financial Intelligence Unit under Section 43 GwG. Failure to appoint or significant breaches are administrative offences under Section 56 GwG with fines up to 150,000 euros, in serious cases up to 5 million euros or 10 percent of annual turnover.
Core duties
- Prepare and update the company-specific risk analysis under Section 5 GwG annually.
- Implement internal procedures and controls under Section 6 GwG including KYC and screening.
- Conduct customer due diligence under Sections 10 to 17 GwG including PEP and sanctions screening.
- Monitor transactions and detect anomalies against the customer risk profile.
- Submit suspicious activity reports to the FIU via goAML without delay under Section 43 GwG.
- Operate the internal whistleblowing channel under Section 6 paragraph 5 GwG.
- Train staff at least annually and document attendance.
- Report to the management board at least once a year and ad hoc on material risks.
- Liaise with BaFin, BAFA, the Rechtsanwaltskammer or the chamber of commerce as applicable.
- Maintain documentation for at least five years under Section 8 GwG.
When appointment is mandatory
Appointment is mandatory for every entity listed in Section 2 GwG, irrespective of size, unless the competent authority grants an exemption under Section 7 paragraph 2 GwG. For credit and financial services institutions under BaFin supervision, appointment is always required and the officer must be on the second management level reporting directly to the board. External AML officers are permitted under Section 7 paragraph 1 sentence 2 GwG for non-bank obliged entities.
- Company is listed as obliged entity under Section 2 GwG
- Bank or financial services institution under KWG or ZAG license
- Crypto-asset service provider under MiCAR
- Real estate agent above 10,000 euros rental or any sales mandate
- Goods dealer accepting cash payments of 10,000 euros or more
- Order by BaFin or the competent authority under Section 50 GwG
Typical sectors
- Banks and credit institutions under KWG
- Payment and e-money institutions under ZAG
- Life and accident insurers under VAG
- Asset managers and capital management companies under KAGB
- Real estate agents and property developers
- Crypto-asset service providers under MiCAR
- Notaries, tax advisors and auditors in transaction mandates
- High-value goods dealers including art, gold and luxury vehicles
- Family offices and trust services
- Fintech, BNPL and embedded finance providers
How CIVAC supports the AML officer
CIVAC delivers a Section 7 GwG-ready workspace covering risk analysis, KYC, transaction monitoring escalation and FIU goAML preparation. The risk analysis module reflects the BaFin AuA risk factors and produces a board-ready report under Section 5 GwG. KYC workflows cover natural persons, legal entities, beneficial owners under the Transparenzregister and PEP screening against sanctions and adverse media lists.
Frequently asked questions
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