Germany Government Prepares AML Supervision Overhaul

Robert Henrici provided his expertise in white collar crime matters in an article by Vixio. The story covers the German government’s efforts to improve its approach to money laundering, with Germany’s finance minister saying he wants to “follow the money.” Robert said that the notion of following the money “is what AML legislation is all about."

Robert acknowledged that Germany's current system is one that is not working perfectly, and this is due to a number of reasons.

"What we deem as money laundering has been broadened extremely due to EU and local developments as well. Money laundering is always a derivative of some other crime…whereas in the early days, this other crime was from a rather confined universe of crimes, such as trafficking. This has broadened to today's system where basically any crime can qualify as such other crime for the purposes of money laundering," Robert explained.

Robert also pointed out that the reporting requirement has an extremely low hurdle in Germany. "It is a very broad regime and this results in hundreds of thousands of reports being filed with the regulators. The bar is very low, but the sanctions can be serious," he said. "The failure to comply properly may result in drastic consequences for firms and banks and, therefore, large volumes of STRs are being filed with the regulators."