The effective fight against money laundering is one of the greatest challenges facing Germany’s financial system and its security architecture. With the new draft bill for the Customs Financial Integrity Act (Zollfinanzgerechtigkeitsgesetz – ZFG), published by the German Federal Ministry of Finance on 3 March 2026, a comprehensive modernisation initiative is being launched that goes far beyond traditional customs responsibilities. The focus lies on strengthening the structures for combating money laundering and financial crime in a holistic manner. What exactly will change and why is this considered a milestone? An overview.
Table of Contents
1. Background: Change and New Requirements
In recent years, both international requirements – in particular the recommendations of the Financial Action Task Force (FATF) – and increasingly complex economic and geopolitical risks have reinforced the need for a fundamental modernisation of the German customs administration and its actors in the field of financial crime.
The ZFG is a key component of the government’s “Customs 2030” initiative and specifically addresses criticism and areas for improvement identified during Germany’s FATF evaluations in 2021/2022, while also preparing for the next review scheduled for 2028.
2. New Structures – Specialised Units and Improved Coordination
The ZFG significantly strengthens the organisational and personnel resources of the customs administration, including the Financial Intelligence Unit (FIU) operating within it.
A central element is the establishment of specialised investigative units within local customs authorities for complex cases of international money laundering. These specialised units are tasked with proactively identifying and investigating large-scale and cross-border money laundering cases involving a German nexus.
Close coordination with the FIU will ensure fast and secure data exchange as well as the use of investigative intelligence. This integrated approach is intended to significantly enhance operational capabilities and overall effectiveness.
3. Legislative Changes to the German Anti-Money Laundering Act (GwG)
Of particular importance for obliged entities and supervisory authorities are the numerous amendments to the German Anti-Money Laundering Act (Geldwäschegesetz – GwG) proposed by the ZFG:
- Expansion of the scope of obliged entities:
Financial holding companies will explicitly become obliged entities under the GwG from 1 January 2027. As a result, the GwG will apply directly to them, while the AML obligations under the German Banking Act (§ 25l Kreditwesengesetz – KWG) will no longer apply. - Clarification of suspicious activity reports:
The concept of a reportable predicate offence will be redefined. In the future, a mere suspicion of an “unlawful act within the meaning of § 261 of the German Criminal Code (Strafgesetzbuch – StGB)” will suffice to trigger a suspicious activity report. A fully established criminal offence will no longer be required. While this may lead to an increase in reporting volumes, it strengthens the rule of law and ultimately the integrity of the financial market. - New transparency and verification requirements:
The transparency register will be further strengthened. New verification obligations will apply with regard to representation rights and compliance with reporting obligations. Missing entries will in future be considered an indicator of increased money laundering risk and must be taken into account in the risk management systems of obliged entities. - Expanded access rights and new procedures:
The newly introduced § 23a GwG establishes a right of access to the transparency register for parties with a legitimate interest, implementing the requirements of the EU Anti-Money Laundering Directive (AMLD6).
4. Enhanced Cooperation and Technological Modernisation
In addition to personnel and structural measures, the ZFG promotes the digital expansion of investigative and analytical capabilities.
The objective is more efficient networking between federal and state authorities, customs authorities and other actors involved in combating money laundering. In the future, data quality, interoperability and the ability to take timely action will be key priorities – also in response to international criticism and EU requirements.
Conclusion
At this stage, the ZFG is still only a draft bill. As the consultation phase is now beginning, it is not yet clear what the final form of the Customs Financial Integrity Act will look like.
However, one thing is certain: with the ZFG, Germany is taking an ambitious and long-overdue step towards a more future-proof and effective system for combating money laundering. The modernisation of structures, the expansion of the scope of obliged entities, more precise reporting obligations, and increased transparency and cooperation set new standards for compliance and enforcement.
For obliged entities in the financial sector in particular, this means expanded verification and documentation requirements, but also opportunities to optimise internal processes. The coming months and years will show how quickly and effectively the new mechanisms will take effect – but the legislative framework has now been set.
