Search
Contact
Symbolbild zur Geldwäscheprävention: Hochhausfassade
21.02.2025 | KPMG Law Insights

Money laundering prevention: BaFin calls on financial sector to act

The German Federal Financial Supervisory Authority (BaFin) is calling on the financial sector to pay greater attention to money laundering prevention. In its report “Risks in Focus 2025”, it warns of the dangers associated with new business models and innovative technologies. BaFin emphasizes that a lack of protection against money laundering particularly endangers the stability of the financial market. Where exactly are the dangers and what preventative measures should financial institutions take?

Innovative business models harbor risks

BaFin demands: Financial market players should take stronger action against terrorist financing and illegal money transfers from 2025. Due to the geopolitical environment, the risk of financial market players being misused for money laundering and terrorist financing remains high. As a result of geopolitical developments, the Hawala money transfer system, for example, has also gained in importance. It operates without the involvement of banks and without state approval or supervision. With Hawala, there are no receipts and you don’t need an account. The system is based on trust and secrecy and thus offers ideal conditions for illegal money transfers.

Methods such as loan fronting also increase the risk of money laundering and terrorist financing. Here, the bank only acts as a formal lender; the financing actually comes from an external third party. If the bank does not adequately check where the money comes from, it can inadvertently become involved in money laundering.

Technological developments make combating money laundering more difficult

Rapid technological innovations are opening up additional ways for criminals to disguise their illegal financial flows. Financial regulators continue to focus their attention on cryptocurrencies, as their anonymous structure poses an increased risk of abuse. The European Union has introduced stricter regulations to control crypto asset transfers with the Money Transfers Regulation as of December 30, 2024. (The new regulations entail additional tasks for financial institutions).

The increased use of virtual IBANs (vIBANs) is becoming another technological challenge in the fight against money laundering. Although companies benefit from the increased flexibility of vIBANs in their banking transactions, this also increases the risk of payment flows being concealed and regulatory controls being circumvented.

BaFin strengthens supervisory measures to prevent money laundering

BaFin has announced that it will step up its supervision and auditing activities to combat money laundering and terrorist financing. It is planning at least 75 special audits in the banking and non-banking sector for 2025. The focus will be on credit and payment institutions with an increased risk of terrorist financing.

BaFin is also preparing for the new European supervisory structure. The Anti Money Laundering Authority (AMLA) will improve supervision as an overarching anti-money laundering authority in cooperation with national authorities.

The field analysis of the use of vIBANs in Germany is another core project. This analysis enables the early identification of business models with a high risk of money laundering and the development of targeted countermeasures.

Recommendations for action to prevent money laundering for financial institutions

Financial institutions have increased due diligence obligations, particularly in the areas of KYC processes and identity verification. AI-supported analysis tools support the early detection of suspicious patterns and optimize transaction monitoring. Regular training increases employees’ awareness of new money laundering methods.
Close cooperation with the supervisory authorities is recommended. Internal audits and risk assessments ensure that compliance processes are regularly reviewed and adapted to new regulatory requirements.

Conclusion: Increasing requirements for financial institutions

The BaFin report highlights the growing challenges for financial institutions in the prevention of money laundering in 2025. Geopolitical developments, technological advances and regulatory measures are increasing the demands on compliance and risk management. However, the expansion of internal control systems can ensure compliance with regulatory requirements and help to protect the integrity of the financial market.
BaFin monitors compliance with money laundering prevention measures and promotes continuous process optimization at financial institutions. The effectiveness of the new regulatory approaches and increased European cooperation in the fight against money laundering will become apparent in the future.

 

Explore #more

03.10.2025 | Deal Notifications

KPMG Law and KPMG support the restructuring of Grou-pe CAT in Germany

KPMG Law Rechtsanwaltsgesellschaft (KPMG Law) and KPMG AG Wirtschaftsprüfungsgesellschaft (KPMG) advised Groupe CAT on comprehensive restructuring measures with a cross-service team. Over a period of…

02.10.2025 | Deal Notifications

KPMG Law advises Epitype GmbH and MDG Molecular Diagnostics Group GmbH on the acquisition of significant assets of oncgnostics GmbH

KPMG Law Rechtsanwaltsgesellschaft mbH (KPMG Law) provided comprehensive legal advice to Epitype GmbH, a company of the Dresden-based MDG Group, on the formation and subsequent…

02.10.2025 | In the media

KPMG Law Statement in ZEIT for entrepreneurs: We’ll take the 500 billion!

German construction companies are asking themselves: how quickly will the money come from the government? And they are worried that only the giants will benefit.…

01.10.2025 | KPMG Law Insights

Federal Network Agency reforms special network charges for industry and commerce

The Federal Network Agency is planning a fundamental reform of the special network charges for energy-intensive companies. Any change to the current privilege regime entails…

30.09.2025 | In the media

KPMG Law dominates the top 100 list of the new law firm monitor with eight lawyers

KPMG Law Rechtsanwaltsgesellschaft mbH (KPMG Law) occupies an outstanding sixth place in the overall evaluation of the TOP 100 law firms in the current diruj…

29.09.2025 | KPMG Law Insights

MiSpeL draft: New funding for energy storage systems and charging points

On September 18, 2025, the Federal Network Agency published a draft for the “Market integration of storage systems and charging points” (MiSpeL for short). For…

29.09.2025 | KPMG Law Insights

Organizing the transformation and spin-off of corporate real estate with legal certainty

When real estate portfolios are to be transformed or spun off, the economic success depends heavily on the legal preparation. Complex legal issues often arise,…

25.09.2025 | KPMG Law Insights

MaGo update – roadmap for implementing the new requirements

On 14 July 2025, BaFin revised the circular “Minimum requirements for the business organization of insurance companies under Solvency II” (MaGo for SII-VU) and published…

25.09.2025 | KPMG Law Insights

Foundation register – launch to be postponed from 2026 to 2028

The reform of foundation law, which came into force in July 2023, created a nationwide foundation register based on the commercial register. This was actually

24.09.2025 | In the media

KPMG Law Statement in In-house Counsel: Leveraging potential

The role of the legal department in the company has changed significantly in recent years. Its importance is high. However, it is also increasingly becoming…

Contact

Isabelle Knoche

Senior Manager

THE SQUAIRE Am Flughafen
60549 Frankfurt am Main

Tel.: 069 951195200
iknoche@kpmg-law.com

Pedro Domingo Hernández López

Manager

Tersteegenstraße 19-23
40474 Düsseldorf

Tel.: +49 211 4155597 921
phernandezlopez@kpmg-law.com

© 2024 KPMG Law Rechtsanwaltsgesellschaft mbH, associated with KPMG AG Wirtschaftsprüfungsgesellschaft, a public limited company under German law and a member of the global KPMG organisation of independent member firms affiliated with KPMG International Limited, a Private English Company Limited by Guarantee. All rights reserved. For more details on the structure of KPMG’s global organisation, please visit https://home.kpmg/governance.

 KPMG International does not provide services to clients. No member firm is authorised to bind or contract KPMG International or any other member firm to any third party, just as KPMG International is not authorised to bind or contract any other member firm.

Scroll