Germany's Federal Financial Supervisory Authority (BaFin) has launched a hearing on a planned general administrative act to withdraw all previously granted exemptions from requirements under the German Anti-Money Laundering Act (GwG), with effect from 10 July 2027. The withdrawal would cover exemptions issued on the basis of Section 1(1) GwG in the versions in force up to 20 August 2008 for obliged entities within the meaning of Section 2(1) Nos. 1 to 9 GwG, including exemptions issued by BaFin’s predecessor, the Federal Banking Supervisory Office. BaFin links the move to Regulation (EU) 2024/1624 on preventing the use of the financial system for money laundering or terrorist financing, which does not contain an equivalent provision to the former GwG exemption rule, and notes that Article 6 of the EU regulation sets a new, narrower framework for any exemptions a member state may choose to provide. Comments on the proposed general administrative act can be submitted until 20 June 2025. BaFin intends to publish the general administrative act on its website, with notification deemed to occur the day after publication.

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