Money laundering prevention in the non-financial sector

The Anti-Money Laundering Act (AMLA) applies not only to banks and financial institutions, but also explicitly to a wide range of companies in the non-financial sector. Anyone who brokers real estate, deals in works of art, or sells precious metals, jewelry, watches, or high-value goods such as automobiles or boats is classified as a “reporting entity” under the GwG—and must implement the corresponding due diligence obligations, risk analyses, and internal safeguards. The “ training ” provides a comprehensive overview of the current European and national legal frameworks, explains the basic principles of money laundering prevention—particularly the risk-based approach—and outlines the specific obligations this entails for your industry and your company. Anyone who is unaware of these obligations risks substantial fines and significant reputational damage—because ignorance is no defense against punishment.

Risk analysis is the first and most important step in implementing the Anti-Money Laundering Act (GwG): It determines which customers, transactions, and business relationships within your company pose an elevated risk of money laundering—and thus, what measures must be taken. The “ training ” (Risk Analysis Guide) shows how to methodically structure a risk analysis, how to conduct customer profile assessments, and how to derive internal safeguards—including group-wide procedures—from these findings. It also addresses the question of when and how a money laundering officer must be appointed and what documentation and retention requirements the law mandates. Once this process has been carried out properly, you not only lay the foundation for an effective prevention program but also establish the basis for a robust defense against regulatory authorities in the event of an audit.

Customer due diligence obligations are at the heart of the Anti-Money Laundering Act (GwG): They govern how politically exposed persons ( customers ) and persons of interest ( business partners ) must be identified, verified, and classified—and to what extent this must be done. The “ training ” addresses all three levels of due diligence obligations using concrete examples from the non-financial sector: When are general due diligence obligations sufficient? When are simplified measures permissible? And when are enhanced due diligence obligations mandatory—for example, in the case of politically exposed persons, high-risk countries, or unusual transaction structures? Furthermore, the report explains the conditions under which due diligence obligations can be contractually outsourced to third parties—an aspect that offers significant potential for efficiency gains in practice but also has clear legal limits.

Money laundering often involves complex corporate structures, fiduciary relationships, or straw men that conceal the true owners. The Anti-Money Laundering Act (GwG) therefore requires companies to identify the beneficial owner—that is, the natural person who is ultimately behind a transaction or business relationship. The “ training ” explains how beneficial owners are defined under the GwG, what documentation requirements apply, and how the Transparency Register can be used as a tool in this process. It also covers the transparency obligations that apply to companies themselves, what to consider when reporting discrepancies, and the specific requirements for real estate transactions—an area that has been subject to particularly intensive scrutiny by regulatory authorities in recent years.

Any person subject to the Anti-Money Laundering Act (GwG) who suspects money laundering or terrorist financing is required to report it to the Financial Intelligence Unit (FIU)—ideally before the suspicious transaction is carried out, if possible. The “ training ” explains how to use the FIU’s electronic reporting portal, what information a suspicious activity report must contain, and how the entire suspicious activity reporting process is structured. It also addresses the potential consequences of failing to file a report—and how you can protect yourself and your company through careful documentation. Using best-practice examples of suspicious transactions, you’ll learn to recognize typical patterns and act quickly and correctly in an emergency.