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German FIU Lists Obligated Reporting Entities Under Anti-Money Laundering Act

The German Financial Intelligence Unit (FIU), hosted at the Zoll (Customs) authority, publishes an informational webpage listing all categories of entities obligated to file suspicious activity reports under the Anti-Money Laundering Act (Geldwäschegesetz, GwG). The page enumerates both reporting entities ('Verpflichtete') and their respective supervisory authorities ('Aufsichtsbehörden'), citing sections 2 and 50 of the GwG as the governing statutory provisions.

Germany Requires AML Registration in goAML Web by Jan. 1, 2024

Germany's Financial Intelligence Unit (FIU) has issued guidance confirming that all obliged entities under § 2 Abs. 1 of the Anti-Money Laundering Act (GwG) must register in the electronic reporting portal goAML Web by January 1, 2024, regardless of whether a suspicious transaction report has been filed. Affected professionals include lawyers, tax advisors, auditors, patent attorneys, and other listed practitioners under § 2 Abs. 1 Nr. 10–12 GwG, each of whom must register individually as a separate obliged entity — registration of a law firm or partnership does not satisfy the requirement. Professionals with multiple qualifications may only register under one primary professional activity.

Submit Suspicious Activity Reports via goAML or Fax

The German Financial Intelligence Unit (FIU) has published operational guidance on submitting suspicious activity reports (Verdachtsmeldungen) under §45 GwG. Since 1 February 2018, reports must be filed electronically via the goAML web portal; fax submission is permitted only for first-time reports, during system outages exceeding two hours, or in urgent cases. The document provides detailed instructions for using the goAML web form and XML upload, plus fallback procedures using official forms 033572/033573 submitted by fax (+49 228 303 98551) or post to Köln.