Mutual Evaluation of Germany: 3rd Follow-up Report

At its June 2014 meeting, the FATF Plenary recognised that Germany had made sufficient progress in addressing the deficiencies identified in its Mutual Evaluation of Germany, and could be removed from the regular follow-up process.

In February 2010, Germany was placed in the regular follow-up process as a result of a partially compliant rating for certain key and core Recommendations in its mutual evaluation report.  Since then, Germany has reported back to the FATF Plenary about the progress it has made in correcting these deficiencies.

The June 2014 follow-up report contains a detailed description and analysis of the actions taken by Germany in respect of all of the Recommendations rated partially compliant and non-compliant.   

Significant measures taken in respect of the key and core Recommendations are :

• Amendments of the Criminal Code by including insider trading and market manipulation as well as counterfeiting and piracy of products as predicate offences to money laundering.
• Amendments of the AML Law to ensure that verification of beneficial ownership is required in all cases and that in cases of low risk, a minimum level of due diligence is still carried out. Germany has also adopted a much broader definition regarding the beneficial owner in the context of a trust arrangement.
• Amendments to a number of other laws to strengthen the overall AML/CFT framework.
• Enhanced cooperation between relevant ministries, regulatory and supervisory authorities as well as other bodies involved in combating money laundering and terrorist financing.

Some shortcomings in the implementation of the technical requirements of the key and core Recommendations concerning the freezing of terrorist assets still remain.  Overall, the level of progress achieved by Germany was considered sufficient to be removed from the regular follow-up process. 

Mutual Evaluation of Germany

Outcomes from the meeting of the FATF Plenary, Paris, 25-27 June 2014