New Suspicious Transaction Reporting guidance released by BaFin and FIU

The document is aimed at providing further clarification on the terms “immediateness” and “completeness” when submitting reports.

Key takeaways include:

• If facts exist that point to circumstances outlined in the Money Laundering Act (GWG), reports should be made on the same or following working day;
• Emphasising the importance of submitting data in the structured formats either through the reporting form or in the XML schema of GoAML; and
• Stressing that reports must be complete containing relevant information on persons, organisations, accounts, and transactions.

✅ Firms with operations in Germany should review the guide to further understand regulatory expectations when submitting suspicious transaction reports.