The Financial Action Task Force (FATF) has published its AML/CFT progress report for Germany. Highlights from this report are shared below.
The FATF acknowledges that Germany has substantially strengthened its AML/CFT system over the past five years. German authorities understand the country’s ML/TF risks well. However, the country must continue to implement reforms and focus on resourcing and prioritization when fighting financial crime. It is also crucial to tackle the risks related to the high use of cash in the country and the use of informal MVTS services.
The FATF report further underscores that Germany has an excellent track record of constructively cooperating with other countries in the fight against ML/TF. However, domestic cooperation and coordination among its 16 states has been challenging. Moreover, there is a scope for improvement in the coordination between the different supervisory and law enforcement authorities.
One of Germany’s strong points is its implementation of non-conviction-based asset confiscation laws that have allowed for the confiscation of large volumes of criminal proceeds. Germany has also improved its collection and use of financial intelligence. However, the country must proactively freeze terrorist assets using the targeted financial sanctions regime. Further, Germany’s newly-introduced Transparency Register is a welcome change, but the country must prioritize resourcing the register this year.