Germany New AML Law: Key Changes Under 6AMLD (2027)

Regulation Name: Geldwäschebekämpfungsgesetz (GwBG)
Date of Introduction: 28 Oct 2026
Region: Germany
Agency: Federal Ministry Of Finance

Germany New AML Law: Understanding the Proposed Geldwäschebekämpfungsgesetz (GwBG)

Germany is preparing a significant overhaul of its anti-money laundering (AML) framework to align national legislation with the European Union’s new AML legislative package. On 28 October 2026, the German Federal Ministry of Finance (Bundesministerium der Finanzen) published a ministerial draft bill proposing the introduction of a new Act on Combating Money Laundering and Terrorist Financing, known as the Geldwäschebekämpfungsgesetz (GwBG).

The proposed legislation seeks to implement the EU’s Sixth Anti-Money Laundering Directive (6AMLD), strengthen the country’s financial intelligence infrastructure, improve beneficial ownership transparency and enhance coordination between national supervisory authorities. It also introduces new mechanisms for accessing real estate ownership information, expands the powers of Germany’s Financial Intelligence Unit (FIU) and establishes additional enforcement measures.

The proposed law forms part of the broader EU AML legislative package adopted on 31 May 2024, which aims to create a more harmonised approach to preventing and detecting money laundering and terrorist financing across member states.

For financial institutions, designated non-financial businesses and professions (DNFBPs), crypto-asset service providers and other AML-obliged entities, these developments signal important changes to Germany’s regulatory and supervisory environment.

With the existing German Money Laundering Act (Geldwäschegesetz or GwG) scheduled to be repealed on 10 July 2027, compliance teams should begin assessing the implications of the proposed framework and preparing for the transition.

What Is Germany’s Proposed New AML Law (GwBG)?

The Geldwäschebekämpfungsgesetz (GwBG) is a proposed German legislative framework designed to implement the EU’s Sixth Anti-Money Laundering Directive (Directive (EU) 2024/1640) and introduce the national measures necessary to support the application of the EU Anti-Money Laundering Regulation (Regulation (EU) 2024/1624).

Published by the German Federal Ministry of Finance on 28 October 2026, the draft proposes replacing the existing Geldwäschegesetz (GwG) with a new national law governing AML/CFT prevention, financial intelligence, supervisory coordination, beneficial ownership transparency and enforcement.

The legislation also incorporates requirements arising from the establishment of the European Anti-Money Laundering Authority (AMLA) and the modernisation of EU financial information-sharing mechanisms.

The proposed GwBG contains 122 provisions organised into eight principal sections:

1. General provisions on AML prevention.

2. Specific AML prevention requirements.

3. Transparency Register.

4. Central access point for real estate information.

5. Financial Intelligence Unit (FIU).

6. AML supervision.

7. Confidentiality, cooperation and data protection.

8. Administrative fines and transitional provisions.

Unlike a simple amendment to the existing German AML framework, the proposed legislation establishes a broader institutional and operational structure for combating money laundering and terrorist financing.

Why Is Germany Introducing a New AML Framework?

The proposed legislation responds to the EU AML legislative package adopted on 31 May 2024, which introduced a more harmonised European approach to financial crime prevention.

The package comprises four major legal instruments:

These instruments address several longstanding challenges in European AML supervision, including inconsistent national implementation, fragmented financial intelligence, limited transparency around beneficial ownership and difficulties accessing financial information across borders.

The proposed German legislation seeks to address these challenges through national implementation measures and institutional reforms.

An important distinction is that the EU AML Regulation will apply directly across member states from 10 July 2027. Germany’s proposed GwBG primarily establishes the national arrangements necessary to implement 6AMLD and support the application of the directly applicable EU regulations.

10 Key Changes Under Germany’s Proposed New AML Law

The proposed GwBG introduces several developments that could significantly influence how AML obligations are administered and supervised in Germany.

1. Replacement of the Existing German Money Laundering Act

One of the most significant changes is the proposed repeal of Germany’s existing Money Laundering Act (Geldwäschegesetz – GwG).

The draft proposes introducing the Geldwäschebekämpfungsgesetz (GwBG) as the country’s new national AML/CFT legislative framework.

The transition is scheduled for 10 July 2027, aligning with the application date of the EU AML Regulation.

The new legislation will consolidate national provisions relating to:

• AML/CFT prevention and risk management.

• Transparency Register administration.

• Beneficial ownership reporting and verification.

• Access to real estate ownership information.

• FIU responsibilities and financial intelligence.

• Supervisory authorities and enforcement.

• Administrative penalties and cooperation mechanisms.

This change is particularly important because the new framework will operate alongside the directly applicable EU AML Regulation rather than simply reproducing the existing national AML requirements.

Compliance implications: Financial institutions and other obliged entities should review their existing AML policies, internal procedures and regulatory compliance frameworks to identify provisions that may require updating under the new legislative structure.

2. Changes to the Scope of AML-Obliged Entities

The proposed GwBG clarifies and supplements the categories of entities subject to AML obligations.

Article 3 of Regulation (EU) 2024/1624 establishes the principal categories of obliged entities. The German draft additionally identifies certain entities under national law.

These include:

• Certain deposit-taking institutions.

• Specific financial services institutions.

• Certain securities institutions.

• Institutions providing qualified crypto custody services.

• Institutions maintaining crypto-securities registers.

The draft also provides for exemptions in certain circumstances.

For example, specific gambling operators are excluded from the relevant obligations under the proposed national provisions. It also establishes a mechanism through which professional football clubs operating below the highest national league may potentially receive exemptions where their activities present demonstrably low money laundering and terrorist financing risks.

Certain limited financial activities may also qualify for exemptions subject to specified conditions, including transaction thresholds, turnover limitations and risk assessments.

Compliance implications: Businesses should reassess their regulatory classification and determine whether their activities fall within the scope of the new AML framework. This is particularly relevant for financial services providers, crypto businesses and entities operating in sectors where national exemptions may apply.

3. Strengthening Beneficial Ownership Transparency Through the Transparency Register

Beneficial ownership transparency is one of the central themes of the proposed German AML reforms.

The draft introduces several changes to the Transparency Register (Transparenzregister), which contains information about the beneficial owners of legal entities and other relevant arrangements.

The proposed reforms seek to improve the accuracy, completeness and accessibility of beneficial ownership information.

Key developments include:

Enhanced verification of beneficial ownership information

The authority responsible for maintaining the Transparency Register will receive stronger powers to verify information submitted by reporting entities.

Where information remains inaccurate or does not meet the applicable requirements, the authority may withhold confirmation of registration until the deficiencies are corrected.

Integration of information from other registers

The draft provides for pre-population of certain declarations using information obtained from other registers and previous submissions.

However, pre-population will not remove the underlying reporting entity’s obligation to submit the required information.

Screening against targeted financial sanctions

The register-maintaining authority will also examine whether registered individuals or legal entities are associated with targeted financial sanctions.

Where relevant, the affected entity may receive an appropriate indication in the register.

Stronger enforcement of reporting obligations

The draft introduces administrative enforcement procedures for entities that fail to comply with their beneficial ownership reporting obligations.

These include measures to compel compliance and provisions allowing certain entities or legal arrangements to be made inactive.

Improved handling of discrepancies

The proposed framework strengthens procedures for identifying and investigating inconsistencies between beneficial ownership declarations and information held in other registers.

These changes are particularly relevant to financial institutions conducting customer due diligence (CDD), enhanced due diligence (EDD) and corporate ownership assessments.

For AML compliance teams, access to accurate beneficial ownership information is essential for identifying complex ownership structures, detecting concealed control relationships and assessing exposure to sanctioned individuals or entities.

4. Introduction of a Central Access Point for Real Estate Information

The proposed GwBG introduces a Central Access Point for Real Estate Information (Zentrale Zugangsstelle für Informationen über Immobilien).

This initiative is intended to improve the availability of property ownership information for competent authorities, particularly law enforcement agencies.

Under the existing fragmented information environment, relevant real estate information is distributed across different registers and information systems.

The proposed central access point aims to facilitate faster and more coordinated access.

Information made accessible through the proposed framework includes:

• Property address and characteristics.

• Relevant land registry information.

• Property ownership details.

• Purchase prices.

• Existing charges and restrictions.

• Mortgages and other registered property rights.

The system is expected to become operational in accordance with the 6AMLD implementation deadline of 10 July 2029.

The draft also establishes provisions for data transmission, information access, monitoring and reporting relevant discrepancies to the FIU.

Why this matters for AML professionals

Real estate is a recognised channel through which criminal proceeds may be integrated into the legitimate economy.

Complex ownership structures, corporate vehicles, nominees and cross-border arrangements can make it difficult to establish the actual individuals controlling or benefiting from a property.

Centralised access to property-related information could help competent authorities connect ownership records with financial intelligence, identify suspicious asset relationships and support investigations into potential money laundering.

For financial institutions, this development reinforces the importance of considering property ownership and associated corporate structures when assessing customer risk.

5. Expanded Powers and Responsibilities of Germany’s Financial Intelligence Unit

The proposed legislation introduces extensive changes to the responsibilities and information-access capabilities of Germany’s Financial Intelligence Unit (FIU), formally known as the Zentralstelle für Finanztransaktionsuntersuchungen.

The FIU plays a central role in receiving, analysing and disseminating financial intelligence relating to suspected money laundering and terrorist financing.

The draft expands its responsibilities in several areas.

Expanded information sources

The FIU’s analytical activities will incorporate additional information received from relevant authorities and institutions, including:

• Transparency Register information.

• Information from the central real estate access point.

• Reports from supervisory authorities.

• Suspicious transaction reports.

• Relevant financial and law enforcement information.

Joint analysis with other EU FIUs

The proposed framework provides for joint analyses with FIUs in other EU member states.

This is intended to facilitate the examination of financial activity involving multiple jurisdictions and improve cooperation in complex investigations.

Expanded information access

The draft establishes provisions governing the FIU’s access to information held by domestic public authorities and obliged entities.

It also addresses access to law enforcement information, financial data and account-related information.

Immediate measures and monitoring orders

The proposed law includes provisions concerning immediate measures and monitoring orders as part of the FIU’s expanded operational framework.

Improved feedback mechanisms

The legislation also provides for feedback to obliged entities and authorities regarding relevant findings and developments.

For reporting institutions, this could contribute to better understanding of emerging financial crime patterns and the effectiveness of suspicious activity reporting.

Compliance implications: Financial institutions should examine their suspicious transaction reporting processes, internal escalation mechanisms, data quality standards and ability to respond to FIU information requests.

6. Strengthening AML Supervision Through BaFin and Coordinated Supervisory Mechanisms

Another significant component of the proposed GwBG concerns the organisation and coordination of AML supervision.

The draft establishes a Central Coordination Office for AML Supervision (Zentrale Koordinierungsstelle Geldwäscheaufsicht) within the Federal Financial Supervisory Authority (BaFin).

Its purpose is to improve coordination among the various authorities responsible for AML supervision.

The proposed framework introduces:

• Cross-sector supervisory coordination.

• Sector-specific supervisory coordination.

• Improved cooperation between federal and state authorities.

• Information exchange between supervisory bodies.

• Coordination of supervision in the non-financial sector.

• Cooperation with the European AML Authority.

• Supervisory colleges for financial and non-financial sectors.

The draft also addresses cooperation between authorities supervising entities that operate across EU member states and in third countries.

The shift towards coordinated, risk-based supervision

The legislation reinforces the risk-based approach to AML supervision.

Authorities are expected to consider the money laundering and terrorist financing risks associated with different sectors and entities when allocating supervisory resources and determining the intensity of supervisory activities.

For financial institutions and DNFBPs, this means that effective AML compliance should extend beyond maintaining policies and procedures.

Institutions should be able to demonstrate that their controls are appropriate to their risk exposure and that identified weaknesses are addressed effectively.

7. Introduction of New Requirements for Real Estate Transactions

The proposed legislation introduces additional safeguards against the use of cash and other high-value assets in German real estate transactions.

Under the proposed GwBG, consideration for the purchase or exchange of domestic real estate cannot be paid using:

• Cash.

• Crypto-assets.

• Gold.

• Platinum.

• Precious stones.

The restriction also applies to certain acquisitions of shares in companies and cooperatives whose assets include domestic real estate.

The draft introduces additional requirements for demonstrating that payment has been made through permitted means.

Notaries responsible for submitting applications to register property ownership will have to examine the plausibility of the relevant payment evidence before proceeding with the registration application.

The legislation also contains specific procedures for situations where payment is made in instalments or after the initial registration application.

Certain verification requirements do not apply where the consideration does not exceed €10,000 or where payment is made through the notary’s escrow account, subject to the provisions of the draft.

The objective is to improve the traceability of funds used in property acquisitions and reduce opportunities for concealing criminal proceeds through real estate transactions.

8. Modernisation of Bank Account Registers and Financial Information Sharing

The proposed legislation also addresses access to financial information held in bank account registers across the European Union.

Through amendments to the Federal Criminal Police Office Act (Bundeskriminalamtgesetz), the draft proposes enabling the Federal Criminal Police Office (BKA) to conduct automated searches through the interconnected bank account register system.

The information covered includes:

• Bank accounts.

• Crypto-asset accounts.

• Safe-deposit boxes.

The proposed changes are intended to improve the ability of competent authorities to identify relevant financial accounts and associated information across EU jurisdictions.

The draft also addresses the introduction of a standardised format for transmitting financial transaction records.

This is particularly relevant to cross-border financial investigations, where differences in data formats and information systems can create operational difficulties.

Compliance implications: Financial institutions and crypto-asset service providers should monitor developments concerning financial data standardisation, reporting interfaces and information-sharing requirements.

9. New Requirements for Internet Gambling and Bearer Shares

The proposed legislation also addresses specific activities and structures that may present money laundering risks.

Internet gambling

The draft introduces additional requirements for obliged entities offering or arranging online gambling services.

These include requirements for establishing player accounts before allowing individuals to participate in online gambling.

It also contains provisions governing the acceptance of deposits and other repayable funds into player accounts, together with related recordkeeping and retention requirements.

Bearer shares

The draft incorporates the EU AML Regulation’s prohibition on issuing bearer shares and the requirement to convert existing bearer shares in accordance with the applicable framework.

These measures are intended to improve transparency regarding ownership and control of legal entities.

For AML professionals, these developments reinforce the importance of assessing ownership opacity and the ability to establish the identity of individuals exercising control over corporate structures.

10. Expanded Enforcement, Administrative Penalties and Whistleblower Protection

The proposed GwBG contains a dedicated section addressing administrative offences, penalties and transitional arrangements.

The legislation establishes provisions for penalising violations of:

• The new German AML legislation.

• Regulation (EU) 2023/1113 concerning transfers of funds and certain crypto-assets.

• Regulation (EU) 2024/1624, the EU AML Regulation.

The draft also addresses administrative enforcement measures, periodic penalty payments and cooperation between supervisory authorities.

Another important development concerns the publication of administrative decisions and penalties.

Under the proposed provisions, certain published decisions must generally remain available on the relevant supervisory authority’s website for five years, subject to conditions concerning proportionality, personal data and other protected interests.

The legislation also includes provisions for reporting violations and protecting whistleblowers.

For compliance leaders, these developments highlight the importance of maintaining effective internal controls, documented AML procedures, appropriate oversight and timely remediation of compliance weaknesses.

Key Implementation Dates Under Germany’s Proposed AML Framework

The transition to the new German AML framework is linked to several implementation milestones established under the EU legislative package and the proposed national legislation.

One important transitional provision concerns the FIU’s access to bank account information.

Until the technical implementation of the direct access procedure, and no later than 31 December 2030, the FIU may request the Federal Central Tax Office (Bundeszentralamt für Steuern) to retrieve specified account information from credit institutions.

These milestones mean that implementation will involve more than a single legislative commencement date. Different technological and institutional arrangements will be introduced over several years.

What Should AML Compliance Leaders Do Before July 2027?

The proposed German AML reforms require financial institutions and other obliged entities to evaluate their existing compliance frameworks and identify areas requiring preparation.

Although the final legislative requirements will depend on the enacted legislation and applicable EU regulations, compliance teams can begin addressing several priority areas.

1. Conduct a regulatory gap assessment

Review existing AML policies, procedures and controls against the requirements of Regulation (EU) 2024/1624 and the proposed GwBG.

Identify areas where changes to national legislation, supervisory responsibilities or reporting arrangements could affect existing compliance processes.

2. Review beneficial ownership verification processes

Assess whether existing customer due diligence procedures can identify complex ownership structures and establish the identities of ultimate beneficial owners.

Pay particular attention to:

• Multi-layered corporate structures.

• Foreign legal entities.

• Trusts and similar arrangements.

• Sanctioned individuals and entities.

• Discrepancies between customer declarations and registry information.

3. Strengthen sanctions screening and adverse media monitoring

The proposed changes to the Transparency Register reinforce the importance of identifying connections with targeted financial sanctions.

Institutions should evaluate whether their screening systems can identify relevant individuals, entities and ownership relationships.

Adverse media monitoring can also support the identification of financial crime risks associated with customers and their connected entities.

4. Reassess suspicious transaction reporting

Review the effectiveness of transaction monitoring, internal escalation and suspicious transaction reporting procedures.

Consider whether existing processes provide sufficient data quality, supporting documentation and investigative context for FIU reporting.

5. Evaluate data management and interoperability

The expansion of financial information-sharing mechanisms highlights the importance of maintaining accurate, structured and accessible financial data.

Compliance teams should assess whether their systems can support:

• Reliable customer identification.

• Consistent transaction records.

• Beneficial ownership information.

• Cross-border information requirements.

• Timely responses to regulatory information requests.

6. Prepare for supervisory changes

Financial institutions should monitor developments concerning BaFin’s new coordination responsibilities and the broader supervisory arrangements under the GwBG.

Compliance officers should also ensure that regulatory developments are communicated to senior management and relevant business functions.

7. Establish a regulatory implementation roadmap

Develop an implementation plan covering regulatory assessment, policy updates, technology requirements, employee training and internal control testing.

A structured approach will help institutions prepare for the transition without treating July 2027 as the only relevant milestone.

How the New German AML Framework Could Influence the RegTech Industry

The proposed legislation also has implications for the financial technology and regulatory technology sectors.

As authorities expand their access to financial, corporate and property-related information, financial institutions will increasingly need reliable tools for identifying relationships between customers, transactions, beneficial owners and potential financial crime indicators.

Several technology capabilities are particularly relevant.

Beneficial ownership intelligence: Improved corporate ownership mapping and verification capabilities can help institutions identify ultimate beneficial owners and assess complex corporate structures.

Sanctions and watchlist screening: More comprehensive screening capabilities can support the identification of individuals and entities associated with targeted financial sanctions.

Adverse media monitoring: Monitoring regulatory enforcement actions, financial crime developments and negative news can provide additional context for customer risk assessments.

Transaction monitoring: Enhanced transaction analysis can help identify suspicious financial activity, unusual transaction patterns and potential money laundering indicators.

Entity resolution and network analytics: Connecting individuals, companies, transactions and ownership relationships can help investigators identify networks that may not be apparent through isolated customer or transaction records.

Regulatory data management: Structured data processing and standardised information exchange can support more effective compliance reporting and investigations.

For RegTech providers, the proposed framework highlights the growing importance of integrated AML capabilities that combine screening, monitoring, financial intelligence and entity-level risk analysis.

Frequently Asked Questions (FAQs)

1. What is Germany’s new AML law (GwBG)?

The Geldwäschebekämpfungsgesetz (GwBG) is a proposed German Act on Combating Money Laundering and Terrorist Financing. It is intended to implement the EU’s Sixth Anti-Money Laundering Directive and establish the national arrangements required to support the EU AML legislative framework. It is proposed to replace the existing German Money Laundering Act (GwG) from 10 July 2027.

2. When will Germany’s new AML law come into effect?

The draft proposes that the new GwBG will take effect on 10 July 2027, alongside the application of Regulation (EU) 2024/1624. The proposed framework also includes later implementation milestones, particularly for real estate information access and financial data-sharing infrastructure.

3. What is the difference between 6AMLD and the new German GwBG?

6AMLD (Directive (EU) 2024/1640) is an EU directive requiring member states to establish national mechanisms for preventing and combating money laundering and terrorist financing. The GwBG is Germany’s proposed national legislation implementing that directive and establishing related domestic institutional and supervisory arrangements.

4. What is changing in Germany’s Transparency Register?

The proposed reforms strengthen the verification of beneficial ownership information, introduce checks concerning targeted financial sanctions, improve the exchange of information between registers and establish stronger enforcement procedures for entities that fail to meet reporting obligations.

5. What is Germany’s new Central Access Point for Real Estate Information?

It is a proposed centralised system designed to provide competent authorities with digital access to property and ownership information held across different information systems. The initiative is intended to improve financial crime investigations involving real estate and is linked to the 10 July 2029 implementation deadline.

6. How will the new German AML framework affect the FIU?

The proposed legislation expands the FIU’s responsibilities concerning financial intelligence analysis, cooperation with other EU FIUs, access to relevant information and feedback to reporting institutions. It also provides for joint analyses and additional information-sharing mechanisms.

7. What role will BaFin play under the proposed GwBG?

BaFin will host the proposed Central Coordination Office for AML Supervision. This office is intended to improve coordination among financial and non-financial sector supervisory authorities, support risk-based supervision and facilitate cooperation between federal and state authorities.

8. Does the proposed German AML law introduce a €10,000 cash payment limit?

The €10,000 maximum for cash payments in commercial transactions originates from Regulation (EU) 2024/1624, the EU AML Regulation. It is not a separate national threshold introduced by the proposed GwBG. The draft also contains a distinct restriction on using cash, crypto-assets, gold, platinum and precious stones as consideration for domestic real estate acquisitions.

9. Which businesses should prepare for the new German AML framework?

Financial institutions, crypto-asset service providers, relevant gambling operators, lawyers, accountants, tax advisers, real estate-related obliged entities and other businesses falling within the applicable EU and national AML framework should assess the implications for their activities.

10. Has Germany’s new AML law been enacted?

The document dated 28 October 2026 is a ministerial draft bill (Referentenentwurf) published by the German Federal Ministry of Finance. It should not be treated as enacted legislation. The final requirements will depend on the legislative process and the version ultimately adopted.

Conclusion

Germany’s proposed Geldwäschebekämpfungsgesetz represents an important step in aligning the country’s AML/CFT framework with the European Union’s broader regulatory reforms.

The proposed legislation goes beyond replacing the existing Money Laundering Act. It introduces stronger beneficial ownership verification, improved access to real estate information, expanded FIU capabilities, coordinated AML supervision and enhanced financial information-sharing mechanisms.

For AML compliance leaders, the most important consideration is the shift towards a more interconnected financial intelligence and supervisory environment. Customer due diligence, beneficial ownership verification, sanctions screening, transaction monitoring and regulatory reporting will need to operate within an increasingly coordinated European AML framework.

With the proposed transition scheduled for 10 July 2027, financial institutions and other obliged entities should begin assessing their existing compliance arrangements, identifying regulatory gaps and preparing implementation roadmaps.

Ultimately, the effectiveness of the new framework will depend not only on legislative changes but also on the ability of financial institutions, supervisory authorities and technology providers to translate regulatory requirements into effective financial crime prevention.

For AML professionals, understanding these changes early will be essential to preparing for the next phase of Germany’s AML regulatory landscape.

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