Regulatory Alerts2021-01-27 | Anti-money laundering guidelines for institutions conducting crypto custody business that are newly obliged entities under the German Money Laundering Act (Geldwäschegesetz – GwG)Anti-money laundering guidelines for institutions conducting crypto custody business
BaFin issued these guidelines to clarify anti-money laundering obligations for institutions conducting crypto custody business, which became newly obliged entities under the German Money Laundering Act (GwG) on 1 January 2020. The guidelines mandate a risk-based approach requiring institutions to implement effective risk management systems, conduct customer due diligence tailored to crypto asset risks, and report suspicious transactions electronically to the Financial Intelligence Unit. Compliance further requires appointing a German-based money laundering officer, maintaining FIU registration, and applying simplified or enhanced due diligence measures based on assessed risk levels.
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