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

15.06.2026 | KPMG Law Insights

Higher Fees for Designers Due to Cost Increases? What Clients Need to Know

More and more often, architects and engineers are sending additional invoices to their clients. “The project is dragging on, construction costs are rising, and

12.06.2026 | KPMG Law Insights

12th Amendment to the German Act Against Restraints of Competition: What’s Changing for Transactions, Public Procurement, and Certain Industries

The planned 12th amendment to the German Act Against Restraints of Competition (GWB) is expected to bring several significant changes for businesses, including higher thresholds…

09.06.2026 | KPMG Law Insights

Implementation of the Pay Transparency Directive: what the expert commission recommends

The EU Pay Transparency Directive has been in force since June 2023 and should have been transposed into German…

02.06.2026 | Deal Notifications

KPMG is assisting hpm Henkel Projektmanagement with its integration into the BKW Engineering network

KPMG Law provided exclusive legal counsel to the shareholders of hpm Henkel Projektmanagement regarding the company’s integration into the BKW Engineering network. KPMG Law provided…

02.06.2026 | In the media

KPMG Law quote in Die Welt and Business Insider on the most important changes in June

In June, several changes come into force that will directly affect millions of consumers in Germany. From new rights for online shopping and changes to…

29.05.2026 | In the media

Statement by KPMG Law experts in the Süddeutsche Zeitung on the topic of embedded insurance

Insurance is increasingly being offered when buying cars, cell phones or concert tickets. Embedded insurance is particularly popular when buying electrical devices such as smartphones.…

26.05.2026 | KPMG Law Insights

The industrial electricity price – cost relief with new requirements and verification obligations

The industrial electricity price is in the starting blocks: With the publication of the funding guideline on May 6, 2026, the long-awaited legal framework for…

19.05.2026 | KPMG Law Insights

The amendment to the Environmental Appeals Act is intended to speed up infrastructure projects

The amendment to the Environmental Appeals Act (UmwRG) passed by the Federal Cabinet on January 21, 2026 is intended to speed up infrastructure projects.…

15.05.2026 | KPMG Law Insights

How the EU Inc. is changing the transaction market – five theses for M&A, venture capital and private equity

EU Inc. could noticeably change the transaction market in Europe. This is because it changes central assumptions about social structures. If shares are transferred digitally,…

14.05.2026 | Deal Notifications

KPMG Law advises Deutsche Telekom on BaFin authorization for reinsurance captive

Deutsche Telekom AG has received permission from BaFin to establish a reinsurance captive based in Germany. The license was granted at the end of March…

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

© 2026 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