The Laundromat – March Edition 2026

Welcome to the March edition of The Laundromat newsletter! As already announced in the February issue, today we are sharing part two of the interview with Dr .Lars Haffke on the topic of the new EU AML Regulation. Dr. Haffke is an external Money Laundering Reporting Officer (MLRO), salary partner at pikepartners, lecturer, editor, author and speaker, and has an almost unparalleled understanding of the upcoming changes brought about by the EU AML Regulation.

In this issue, we are focusing on “European alliances” and asked him how he views the cooperation between the Anti-Money Laundering Authority (AMLA) and the German financial supervisory authority BaFin.

Interview with Dr. Lars Haffke – Part 2

Which role does the Anti Money Laundering Authority (AMLA), which was launched in July 2025, play in connection with the new AMLR? Are there already initial results that point, for example, toward consolidation of data management at the European level?

The AMLA will assume the central role in money laundering prevention in Europe. It will not only directly supervise at least 40 institutions starting in 2028 but will also further specify the EU AML Regulation and ensure uniform application by national supervisory authorities.

To achieve this, it will rely in particular on Regulatory Technical Standards (Level 2 regulation) and Guidelines (Level 3 regulation), which are also directly applicable to obliged entities. Across the entire EU AML package (EU AML Regulation, EU AMLA Regulation, EU AML Directive), this will amount to a high double-digit number of documents. Although it will take some time, the first documents have been published in draft form and are available on the AMLA website.

Through these instruments, the AMLA will also harmonize supervision and, among other things, ensure a uniform risk assessment of obliged entities by supervisory authorities. This includes data points, risk models, and calculation methods. Supervisory authorities must also report to AMLA.
One could say that anti-money laundering will become more data driven and therefore somehow more transparent.

In your view, how will cooperation between the German Financial Supervisory Authority BaFin and the AMLA develop in the future? Where does BaFin’s responsibility end, where does AMLA’s begin, and vice versa?

The AMLA will be responsible for shaping the AMLR through RTS and guidelines. BaFin’s current interpretative and application guidance will no longer exist, at least not in its current form. However, supplementary guidance from national supervisory authorities will still be possible.

It is also clear that AMLA will assume direct supervision of at least 40 obliged entities starting in 2028. At least one institution, and likely several, will have their headquarters in Germany. For these, AMLA will take over direct supervision for AML purposes. At BaFin’s request, the AMLA may also assume direct supervision of additional obliged entities. Joint teams made up of AMLA and national supervisory staff will then be formed for supervisory activities.

For all German institutions not directly supervised by AMLA, BaFin will remain the responsible supervisory authority for AML. However, AMLA will oversee the national supervisory authorities in carrying out their tasks and will also take a data driven approach in this area.

For Crypto Asset Service Providers (CASPs), there is currently a separate discussion about whether they should be directly supervised by the European Securities and Markets Authority (ESMA). This remains to be seen.

The precise contours of the cooperation are still emerging. AMLA has only recently begun its work and is not yet fully staffed. BaFin is, of course, taking part in regular exchanges with AMLA and informs obliged entities about the cooperation and related developments at its annual conferences and ad-hoc.

In Case You Missed It: Our AML News Overview

European Public Prosecutor’s Office Uncovers Record Cases of Fraud Involving EU Funds

Even the European Commission has come under scrutiny: in mid‑February, investigators from the world’s first transnational European Public Prosecutor’s Office (EPPO) searched European Commission offices in Brussels over possible breaches of public procurement rules in real‑estate sales. EU officials are alleged to have ignored tendering rules when selling buildings in 2024.

This is already the second major operation within just a few weeks. According to EPPO’s 2025 statistics, the authority is currently conducting 3,602 investigations with an estimated overall damage of 67,27 billion euros – more than ever before. The main drivers are VAT and customs fraud, which account for more than 45 billion euros in estimated damage (see EPPO Annual Report 2025, p. 7). One of the most prominent cases is “Operation Moby Dick”, a cross‑border VAT carousel involving electronic goods, in which several mafia organizations are reported to have been involved (see EPPO Annual Report 2025, p. 5).

Also, in relation to the “NextGenerationEU” COVID‑19 recovery fund, the number of suspected cases is rising: according to EPPO’s 2024 Annual Report, more than 300 active investigations with an estimated damage of over 2,8 billion euros relate to NextGenerationEU funding, mainly under the Recovery and Resilience Facility (source: Süddeutsche Zeitung). Over 300 investigations into subsidy fraud are already under way, and the authority warns that the fraud risk is likely to increase further – especially as billions in funds from the program have yet to be disbursed.​

EPPO’s 2025 report with the latest statistics can be found here.​

Amendments to the German Anti Money Laundering Act (GwG)

On 10 February 2026, amendments to the German Anti‑Money‑Laundering Act (GwG) entered into force, introduced by the Standortförderungsgesetz (StoFöG). They primarily affect the financial sector but also contain important adjustments for other obliged entities. The aim is to strengthen digital supervisory practice and to clarify duties relating to customer identification and access to the transparency register.

• Section 8 (2) sentence 1 GwG – record‑keeping and retention obligations:
  When identifying customers, obliged entities must continue to record the ID document number and issuing authority. This is new: if the authority cannot be identified, they must alternatively record the issue state.​
• Section 23 (1) no. 3 GwG – access to the transparency register:
  In future, any person may access the transparency register if they can demonstrate a legitimate interest. This amendment implements the judgment of the Court of Justice of the European Union of 22 November 2022 (C‑37/20, C‑601/20).​
• Section 51 (11) GwG – supervision and electronic communication:
  In future, supervisory authorities may, by way of a general administrative act, require the electronic submission of notifications, reports or applications. They may also lay down binding technical and organizational requirements for the use of such channels.​

The German amendments to the GwG as of 10 February 2026 can be read in detail here.​

Good News

MONEYVAL Praises Latvia’s Progress in Combating Money Laundering and Terrorist Financing

MONEYVAL’s new country report attests that Latvia has, overall, performed strongly in combating money laundering, terrorist financing and proliferation financing. The report highlights in particular the effective reforms implemented since 2018, the strong performance of the Latvian financial intelligence unit, Latvia’s proactive international cooperation and a transparent register of beneficial owners.​

At the same time, MONEYVAL sees room for improvement in the non‑financial sector, where more risk‑based controls (for example by the tax authority and for lawyers), more proceedings against companies, and greater awareness of terrorist‑financing prevention would further strengthen the system.​

You can find the MONEYVAL report here.

Further Reading

AMLA Consults on Standards to Prevent Money Laundering and Terrorist Financing

AMLA is consulting on three Regulatory Technical Standards to combat money laundering and terrorist financing, which will in future have to be applied directly by companies in the financial and non‑financial sector. The BaFin recommends that companies actively participate in the consultations on the following three standards:

• Business relationships and transactions: criteria for distinguishing between business relationships, occasional transactions and related transactions. Consultation period until May 8, 2026.​
• Customer due diligence: requirements on which information and documents obliged entities must obtain in the course of customer due diligence. Consultation period until May 8, 2026.​
• Supervisory measures and sanctions: criteria for administrative fines, supervisory measures and coercive fines in the event of violations. Consultation period until March 9, 2026.​

Further information on the AMLA consultations is available on BaFin’s website. AMLA has also published initial FAQs, which can be found via this link.

Designing efficient Know Your Business (KYB) processes

Under the forthcoming European Anti‑Money Laundering Regulation (EU‑AMLR), the requirements for corporate due diligence – in particular the verification of ultimate beneficial owners (UBOs) – will be further adjusted. Useful information on efficient KYB processes can be found in the WebID glossary.​