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Appoint or dismiss ("discharge") the Group Money Laundering Officer
If you are both an obliged entity and the parent company of a group under anti-money laundering law, you are obliged to appoint a group anti-money laundering officer and a deputy. The supervisory authority must be notified in advance of the appointment and dismissal of the group anti-money laundering officer and his/her deputy.
The money laundering officer is responsible for drawing up a standardised group-wide strategy for the prevention of money laundering and terrorist financing and for coordinating and monitoring its implementation.
The Group Money Laundering Officer does not replace any money laundering officers that may be required at the companies belonging to the group, but fulfils an additional function.
The Group Money Laundering Officer must create binding cross-company procedures for implementing the obligations under money laundering law in the branches, subsidiaries and group companies in Germany and abroad. He is authorised to issue instructions for their implementation.
As part of his duties, the Group Money Laundering Officer must obtain information on an ongoing basis from the branches, subsidiaries and group companies in Germany and abroad about their compliance with money laundering obligations. Furthermore, he must ensure at regular intervals - including through on-site visits - in particular that the obligations under money laundering law are being complied with and that the necessary measures are being taken and effectively implemented. If necessary, it must also take cross-company measures.
The parent company must ensure that the Group Money Laundering Officer or employees authorised by him are given the authority to obtain audit reports - where available - in relation to all branches, subsidiaries and group companies in Germany and abroad. This authorisation also includes the unrestricted right to carry out spot checks as part of the aforementioned tasks.
The parent company must also ensure that the Group Money Laundering Officer, the employees commissioned by the Group Money Laundering Officer and the Group Internal Audit department have access to all information, documents and files relevant to the fulfilment of money laundering obligations throughout the Group, in particular regarding all customers, beneficial owners and all business relationships and transactions within or outside such business relationships. The Group Money Laundering Officer must take precautions to protect personal data.
Responsible authority
The regional council in whose district you live.
Details
Prerequisite
Obligated parties under the Money Laundering Act
- Only natural or legal persons who are obligated under the Money Laundering Act (GwG) are obliged to report.
Personal reliability and qualifications
- The future money laundering officer and his/her deputy must have the necessary personal reliability and professional qualifications.
Procedure
- As an obliged entity, you notify the supervisory authority in advance of the appointment or dismissal of a group anti-money laundering officer and deputy for your company
- Your notification will be reviewed by the competent authority
- You will receive a final notification
- If the person does not have the required qualifications or reliability, the appointment as group money laundering officer or deputy must be revoked at the request of the supervisory authority and a new person must be appointed
Deadlines
- The notification of the Group Money Laundering Officer and/or the deputy must be made prior to the appointment. There is no deadline, i.e. the notification can also be made at short notice. The notification is intended to give the authority the opportunity to review the qualifications and reliability of the newly appointed group money laundering officer and/or deputy and, if necessary, to promptly object to the appointment.
- The supervisory authority must also be notified in advance of the dismissal ("disengagement") of the group anti-money laundering officer and/or deputy
Required documents
- Notification of the appointment or dismissal of a group money laundering officer or his/her deputy
- Proof of authorisation to report
- Proof of appointment as group money laundering officer
- Proof that the applicant is a member of the company's management (e.g. extract from the commercial register or shareholders' agreement)
- if applicable, a current extract from the commercial register
Registered companies must submit a current extract from the commercial register when submitting their application. Legal entities in the process of being founded (GmbH, AG) submit the articles of association or articles of incorporation.
- The supervisory authority reserves the right to request information on the qualifications of the group money laundering officer (e.g. overview of professional career, evidence of participation in money laundering training events, etc.) and his/her reliability (e.g. in the form of information from the Federal Central Register or, if applicable, from the Central Trade Register).
Costs
none
Processing time
not applicable, this is only an advert
Miscellaneous
none
Detailed information
Legal basis
Gesetz über das Aufspüren von Gewinnen aus schweren Straftaten (Geldwäschegesetzt - GwG):
- § 7 Geldwäschebauftragter
- § 9 Gruppenweite Pflichten
Release note
Machine generated, based on the German release by: Innenministerium Baden-Württemberg, 15.09.2025
