AMLR Requirements and RTS/ITS for the 2nd Line of Defense

FAQ

Frequently Asked Questions

Here you will find the most important answers.

Who is obliged to train employees under the German Money Laundering Act (GwG)?

All "obliged entities" within the meaning of Section 2 GwG. Section 6 (2) no. 6 GwG requires them to regularly instruct their employees on methods of money laundering and terrorist financing and on the applicable obligations. Obliged entities include, among others, credit institutions, insurance companies, financial services providers, tax advisors, auditors, lawyers and notaries in certain activities, real estate agents, trustees, crypto-asset service providers, gambling providers, and traders in goods for cash payments of 10,000 euros or more — for precious metals from as little as 2,000 euros. The obligation covers all employees involved in business processes relevant to money laundering: not only compliance, but also client advisory, sales, and management. Responsibility for implementation usually lies with the AML officer to be appointed under Section 7 GwG.

What will change with the EU anti-money laundering regulation (AMLR) from 2027?

Regulation (EU) 2024/1624 applies directly in all member states from July 10, 2027 — without a national transposition act. Together with the 6th Anti-Money Laundering Directive, it replaces the previous system, which was heavily driven by interpretation. For companies, this means four shifts: uniform obligations throughout the EU instead of national arrangements, direct applicability instead of transposition through national law, closer supervision by the new European authority AMLA based in Frankfurt am Main, and significantly higher requirements for risk management, documentation, and training. The core of the reform is a change of yardstick: in the future, compliance will no longer be measured by policies and descriptions, but by structured, reproducible, and verifiable data.

What fines can be imposed under the new EU anti-money laundering law?

The framework is tiered according to the group of addressees. For credit and financial institutions, the rules provide for fines of up to at least 10 million euros or 10% of total annual turnover, whichever is higher, for serious, repeated, or systematic violations. A different standard applies to the other obliged entities: up to at least twice the benefit derived from the violation, or up to at least 1 million euros. A missed or insufficiently documented training course has a double effect: it is a separate breach of duty and is additionally considered an aggravating factor if a suspicious case occurs that trained employees could have recognized and reported. In the future, AMLA will coordinate supervision centrally — violations will thus become visible across member state borders.

How often must GwG training be repeated?

Ongoing and regular. Section 6 (2) no. 6 GwG requires "regular" instruction without specifying a fixed interval. In practice, an annual cycle has become established as the minimum standard. In addition, training must be provided when specific occasions arise: for new hires, before they take up activities relevant to money laundering; in the event of significant legal changes — for example the application of the AMLR from July 10, 2027; when internal policies are updated; after identified anomalies or suspicious cases. The new EU law raises the bar: training should be continuous, tailored to the respective function, and documented with a complete audit trail.

What requirements does the new EU anti-money laundering law impose on employee training?

Training changes from a supporting measure to a control element of the prevention system. Obliged entities must ensure that their employees understand the risks, know the applicable rules, and are actually able to apply the internal policies. Three criteria shape the requirement: Continuity — ongoing instead of a one-off event; Function-specific focus — tailored to the role and the specific risk environment; Documentation with a complete audit trail — verifiable for the supervisory authority. Training is thus no longer purely an HR matter, but an auditable component of the internal control system — with direct significance for the supervisory assessment.

What should obliged entities look for when choosing GwG online training?

Four criteria are decisive: Professional responsibility — the content should come from named experts with practical experience in anti-money laundering law, not from anonymous standard production; Regulatory currency — the training must reflect the current legal situation as well as the transition to the AMLR from July 10, 2027; Function-specific focus — role-specific tailoring for management, AML officers, client advisory, sales, and compliance, which can be supplemented with internal policies; Proof — every participation with a timestamp, learning assessment, and exportable proof. The Anti-Money Laundering & Counter-Terrorist Financing area at Bridgly comprises 29 training courses: a foundational mandatory training course, industry-specific modules for the individual types of obliged entities, and in-depth courses for AML officers and internal audit.

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AMLR Requirements and RTS/ITS for the 2nd Line of Defense

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Frequently Asked Questions

Train your employees in a legally compliant and verifiable way