Germany's Federal Financial Supervisory Authority (BaFin) issued a general administrative order withdrawing, with effect from 10 July 2027, all exemptions from requirements of the German Money Laundering Act (GwG) that BaFin or its predecessor authority granted under the pre-20 August 2008 exemption regime. The withdrawal covers exemptions issued to obliged entities within the scope of section 2(1) nos. 1 to 9 GwG and is based on section 48(1) of the Administrative Procedure Act. BaFin links the measure to the EU Anti-Money Laundering Regulation (EU) 2024/1624, which does not contain a provision equivalent to the former German exemption rule; BaFin therefore considers the legacy exemptions incompatible with directly applicable EU law from 10 July 2027. While Article 6 of the EU regulation allows member states to exempt certain low-risk financial activities subject to restrictive criteria, BaFin notes that any such carve-out would require German legislation and would likely be significantly narrower than the former GwG regime. The order is deemed notified the day after its public announcement on BaFin’s website, and a challenge can be filed within one month of notification.
BaFin 2025-06-30
Germany's Federal Financial Supervisory Authority withdraws pre-2008 Money Laundering Act exemptions effective 10 July 2027
Germany's Federal Financial Supervisory Authority (BaFin) will withdraw all exemptions from the German Money Laundering Act granted before 20 August 2008, effective 10 July 2027. This decision aligns with the EU Anti-Money Laundering Regulation 2024/1624, which lacks equivalent exemption provisions. BaFin indicates that any future exemptions for low-risk activities would require new German legislation and be more restrictive.