Apply for exemption from the obligation to appoint an anti-money laundering officer
As a financial company, you are obliged to appoint an anti-money laundering officer and a deputy.
Goods traders who trade in high-value goods may be obliged to appoint an anti-money laundering officer by general decree in some federal states.
Under certain conditions, they can be exempted from the obligation to appoint an anti-money laundering officer upon application. It must be ensured that all obligations specified in the Money Laundering Act are complied with even without an anti-money laundering officer.
This includes that you, as an obliged party under the Money Laundering Act, prove that
- all relevant areas of your company are provided with the necessary information to prevent money laundering and that there is no risk of information being lost, especially in the case of a division of labour structure
- following a risk-based assessment, other precautions are taken to prevent business relationships and transactions associated with money laundering or terrorist financing.
Both requirements must be met.
Responsible authority
The regional council in whose district you live.
Contact
Details
Prerequisite
- Obligated parties under the Money Laundering Act: Only natural or legal persons who, as obligated parties under the Money Laundering Act, are required by law or by order of the competent authority to appoint a money laundering officer are eligible to apply.
- Clear internal communication: The flow of information on the topic of money laundering prevention within the company must be guaranteed. Staff must be adequately informed, instructed and monitored.
- Other security measures: Other precautions must be taken to prevent business relationships and transactions that may be related to money laundering or terrorist financing.
Procedure
- The obliged entity shall apply to the competent authority for exemption from the obligation to appoint an anti-money laundering officer.
- The application is reviewed by the competent authority.
- Once the procedure has been completed, the obliged entity receives a decision.
Deadlines
None
Required documents
- Application for exemption from the obligation to appoint an anti-money laundering officer: The application must demonstrate in a comprehensible and justified manner that all obligations specified in the Money Laundering Act will be complied with even without an anti-money laundering officer.
- Proof of authorisation to apply
- Proof that the person submitting the application is a member of the company's management (e.g. extract from the commercial register or shareholders' agreement)
- Risk analysis: assessment of the individual company, customer, product and transaction risk
- Presentation of the internal security measures derived from the risk analysis that make the appointment of a money laundering officer unnecessary.
- If applicable, a current extract from the commercial register: Registered companies should submit a current extract from the commercial register with their application. Legal entities in the process of being established (GmbH, AG) submit the articles of association or articles of incorporation.
Costs
please contact the responsible regional council
Processing time
Approximately 6 weeks
Miscellaneous
none
Legal basis
Gesetz über das Aufspüren von Gewinnen aus schweren Straftaten (Geldwäschegesetz - GwG):
- § 7 Geldwäschebeauftragter
Release note
Machine generated, based on the German release by: Innenministerium Baden-Württemberg, 13.05.2026