Appoint or dismiss ("discharge") the Group Money Laundering Officer

If you are both an obliged entity and the parent company of a group under anti-money laundering law, you are obliged to appoint a group anti-money laundering officer and a deputy. The supervisory authority must be notified in advance of the appointment and dismissal of the group anti-money laundering officer and his/her deputy.

The money laundering officer is responsible for drawing up a standardised group-wide strategy for the prevention of money laundering and terrorist financing and for coordinating and monitoring its implementation.

The Group Money Laundering Officer does not replace any money laundering officers that may be required at the companies belonging to the group, but fulfils an additional function.

The Group Money Laundering Officer must create binding cross-company procedures for implementing the obligations under money laundering law in the branches, subsidiaries and group companies in Germany and abroad. He is authorised to issue instructions for their implementation.

As part of his duties, the Group Money Laundering Officer must obtain information on an ongoing basis from the branches, subsidiaries and group companies in Germany and abroad about their compliance with money laundering obligations. Furthermore, he must ensure at regular intervals - including through on-site visits - in particular that the obligations under money laundering law are being complied with and that the necessary measures are being taken and effectively implemented. If necessary, it must also take cross-company measures.

The parent company must ensure that the Group Money Laundering Officer or employees authorised by him are given the authority to obtain audit reports - where available - in relation to all branches, subsidiaries and group companies in Germany and abroad. This authorisation also includes the unrestricted right to carry out spot checks as part of the aforementioned tasks.

The parent company must also ensure that the Group Money Laundering Officer, the employees commissioned by the Group Money Laundering Officer and the Group Internal Audit department have access to all information, documents and files relevant to the fulfilment of money laundering obligations throughout the Group, in particular regarding all customers, beneficial owners and all business relationships and transactions within or outside such business relationships. The Group Money Laundering Officer must take precautions to protect personal data.