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

21.02.2025 | In the media

Guest article in Betriebs Berater: Overview of regulation for securities institutions

Since the Securities Institutions Act (WpIG) came into force on June 26, 2021, securities institutions have had their own supervisory regime. In addition to the…

18.02.2025 | KPMG Law Insights

AI compliance: important legal aspects at a glance

Human intelligence draws on experience, emotion and intuition. Artificial intelligence (AI), on the other hand, processes vast amounts of data in fractions of a second.…

17.02.2025 | In the media

WirtschaftsWoche honors KPMG Law and Konstantin von Busekist

KPMG Law and Konstantin von Busekist were recognized as TOP Law Firm 2025 and Konstantin von Busekist as TOP Lawyer 2025 in the current WirtschaftsWoche…

17.02.2025 | In the media

Guest article in InfrastrukturRecht: Inability to charge the water concession levy

On 09.10.2024 (9 B 5.24), the BVerwG dismissed the appeal of the City of Kassel against the non-admission of the appeal in the judgment of…

13.02.2025 | Deal Notifications

KPMG Law and KPMG advise Windmöller & Hölscher on the sale of the textile machinery division to Starlinger

KPMG Law and KPMG are advising Windmöller & Hölscher KG (Windmöller & Hölscher) on the sale of its textile machinery division to Starlinger & Co…

13.02.2025 | Deal Notifications

KPMG Law advised LDA Legal Data Analytics GmbH on its cooperation with the publishing house C.H.Beck on the development of the chat book “Frag den Grüneberg”

Digitalization is changing the way legal knowledge is accessed and used. LDA Legal Data Analytics GmbH (LDA) develops AI solutions for the legal sector to…

11.02.2025 | KPMG Law Insights

Receipt of the notice of termination at the usual postal delivery times

In the opinion of the Federal Labor Court (BAG, judgment of June 20, 2024 – 2 AZR 213/23), a letter of termination sent by…

11.02.2025 | KPMG Law Insights

Cooperation between administration and start-ups – legal aspects

The advantages of cooperation between the public sector and start-ups are obvious. The administration is faced with the task of digitizing its own authorities and

10.02.2025 | Press releases

New strategic direction in Legal Operations Advisory at KPMG Law: Legal Operations, Legal Technology and Legal Managed Services to be merged

By further integrating Legal Operations, Legal Technology and Legal Managed Services, KPMG Law is deepening its expertise in this area in order to support clients…

05.02.2025 | In the media

Guest article in Innovative Verwaltung: Municipalities and start-ups – a perfect match!

As with a good marriage, there are also a number of legal aspects to consider in a partnership between the public sector and a start-up.…

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