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Apart from offering expert legal consultancy for local jurisdictions, CMS partners up with you to effectively navigate the complexities of global business and legal environments.

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Money laundering prevention

Prevention of money laundering and terrorist financing – fighting crime together and minimising your risks

CMS – a reliable partner in times of rapid change

As the (financial) world becomes increasingly digital and continues to evolve, it is throwing up a host of challenges and hurdles.

White-collar criminals are taking advantage of precisely this scenario. In response, legislation by the European Union and in Germany is imposing ever-tougher regulatory requirements on economic agents. Companies urgently need the support of competent partners here who can help them to stay abreast of developments and implement regulatory requirements appropriately, thus avoiding legal and reputational risks.

Money laundering and terrorist financing – an issue for you too?

If you or your company are an obligated entity as defined in section 2 (1) of the German Anti-Money Laundering Act (Geldwäschegesetz – GwG), you are bound by an extensive set of obligations under the GwG.

Obligated entities pursuant to section 2 (1) of the GwG include, but are not limited to, credit institutions, real estate agents, insurance intermediaries and traders in goods, as well as lawyers and tax advisors.

Examples of the specific obligations include:

  • Setting up an effective risk management system
  • Preparation of a risk analysis
  • Adoption of safeguards appropriate to the risk
  • Appointment of a money laundering reporting officer
  • Training of employees
  • Compliance with due diligence / KYC obligations.

We provide support across all regulatory requirements and questions

As a reliable partner, we are happy to assist if you have any questions about your obligations under the GwG or need support. 

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Our expertise includes 

  • questions about the transparency register and the associated obligations to register and submit reports 
  • preparing internal policies and guidelines
  • preparing and delivering training of employees and
  • handling internal incidents and suspicious activities.

CMS experts as external money laundering reporting officers

We can also support you around all aspects of outsourcing your obligations under money laundering legislation by offering you the option of transferring some functions to us. This could include serving as your money laundering reporting officer.

CMS as a point of contact for the authorities and source of support during audits by regulatory bodies

In addition, we can assist you when dealing with the authorities and courts.

We provide support if an audit by a (regulatory) agency is pending or if you face a possible search by investigating authorities.

We can also liaise with the authorities on your behalf in our role as external money laundering reporting officers, including dealing with official enquiries.

With our long experience and wide-ranging industry knowledge, we make it easier for you to communicate with the relevant authorities and ensure that your business runs smoothly.

We can also help you with registering to submit suspicious activity reports and with the actual reporting (goAML: Requirement for all parties obligated under the GwG to register (cmshs-bloggt.de)).

We are also happy to support you in the event that administrative offence proceedings are brought against you.

Our specialist practice areas

Events

  • Germany
    24 Feb 2026

    What’s new in AML regulation in Germany and Europe

  • Germany
    03 Mar 2026

    IP Insights webinar series 2026

  • Germany
    19 Mar 2026

    CMS Nordic Health Summit

  • Germany
    23 Mar 2026

    CMS at PTMG Spring 2026

  • Germany
    21 Apr 2026

    On the Pulse webinar series 2026 - Spring

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We provide future-facing legal advice to help your organisation thrive. Combining local market knowledge and a global perspective, and with lawyers in locations worldwide, your organisation benefits from the expertise it needs, even across borders.

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