Analysis of the EBA Report on Virtual IBANs following the entry into force of the new AML Regulation
1. BACKGROUND The International Bank Account Number (“IBAN”) was introduced in 1997 by the International Organisation for Standardization…
Blank slate in anti-money laundering law for insurance holding companies
BaFin’s recently published consultation on an amendment to its Application and Interpretation Guidance (AuA) on the Money Laundering…
AuA 2.0: BaFin consultation on the application and interpretation of the Money Laundering Act
BaFin has published an updated version of its application and interpretation notes on the Money Laundering Act for…
AML package (5) – exception for tied credit intermediaries?
The EU AML package was published in the Official Journal of the European Union on 19 June 2024.…
AML package (3) – New features for obligated parties
Part 4 of our series on the AML package deals with the changes to the group of obligated…
Further step towards the adoption of the EU AML Package
As previously outlined on paytechlaw, the legislative process for the adoption of the AML Package of the EU…
ECJ Judgment: Access to the beneficial ownership register for the general public inadmissible without demonstration of a legitimate interest
In its judgment of 22 November 2022 in Joined Cases C-37/20 and C-601/20, the European Court of Justice…
The more the better? German Finance Minister Lindner’s plans for fighting financial crime
On August 24, 2022, German Finance Minister Christian Lindner outlined his plans for a more powerful fight against…
In the sandbox of money laundering – when will it be opened?
Many who are obliged persons pursuant to the German anti-money laundering law (GwG) are hoping that it will…
Draft Guidelines on remote customer onboarding – EBA to set common EU standards
EBA draft Guidelines on remote customer onboarding On 10 December 2021, the European Banking Authority (EBA) has launched…
KYC and KYB – identification pursuant to Anti-Money Laundering Act | FinTech online course #21
As we have already learned in the last article, the identification of the customer is only one of…
PayTechTalk 41 – What does the Anti-Money Laundering Act actually say?
Often when talking about money laundering, people immediately think of Al Capone. And that is quite accurate, because…
BaFin’s Instructions for the Interpretation and Application of the German Anti-Money Laundering Act (IIA)
On 11 December 2018, the German Federal Financial Supervisory Authority (hereinafter referred to as “BaFin”) published its Instructions…