Mandatory GwG training: how often Section 6 GwG requires training

Mandatory GwG training: who must provide training and on what legal basis?

GwG training is mandatory for obliged entities under Section 2 of the German Money Laundering Act (GwG); for real estate agents and traders in goods, this applies only to certain transactions and above certain thresholds (Section 4 (4) and (5) GwG). The legal basis is Section 6 (2) no. 6 GwG: as an internal safeguard, obliged entities must provide their employees with initial and ongoing training on methods of money laundering and terrorist financing and on the relevant obligations. Training is therefore not merely a recommendation but a legally mandated organizational obligation and part of in-house money laundering prevention.

Obliged entities include credit institutions, financial services providers, insurance undertakings and intermediaries, traders in goods, real estate agents, lawyers, tax advisers, and other groups listed in Section 2 (1) GwG. Obliged entity status is linked to the activity carried out, not to the industry designation.

Limit/exception: Real estate agents must maintain risk management, which includes the internal safeguards under Section 6 GwG (Section 4 (2) GwG), only when brokering purchase contracts and rental or lease contracts with a monthly net rent or lease of at least 10,000 euros (Section 4 (4) GwG). For traders in goods, this applies only to transactions involving works of art from 10,000 euros, to transactions involving precious metals such as gold, silver, and platinum with cash payments from 2,000 euros, and to transactions involving other goods with cash payments from 10,000 euros (Section 4 (5) no. 1 GwG). Anyone who does not fall under the catalog of obliged entities in Section 2 GwG is not subject to a GwG training obligation under Section 6 GwG; voluntary awareness training may nevertheless be useful but does not establish any statutory mandatory character.

Who supervises the training obligation? Financial and non-financial sector

Which authority checks compliance with the training obligation is determined by Section 50 GwG. For the financial sector – for example credit institutions, financial services, payment, and e-money institutions, and crypto-asset service providers – the Federal Financial Supervisory Authority (BaFin) is responsible. Its Interpretation and Application Guidance on the GwG is therefore primarily the authoritative standard of interpretation for these obliged entities.

In the non-financial sector, supervision lies with other bodies: for lawyers, for example, with the competent bar association, for tax advisers with the chamber of tax advisers, for auditors with the Chamber of Public Accountants, for notaries with the president of the respective regional court, and for traders in goods, real estate agents, and other groups with the authorities designated under state law. These specify the training obligation in their own information sheets and administrative practices.

Limit/exception: The practice of training at least annually described below is not prescribed in BaFin's guidance, and that guidance applies only to obliged entities supervised by BaFin; in the non-financial sector, the standard must be aligned on a risk-based basis with the respective competent supervisory authority.

How often is GwG training mandatory?

The GwG does not prescribe a fixed frequency: Section 6 (2) no. 6 GwG requires initial and "ongoing" training but does not name a rigid interval. BaFin specifies this on a risk-based basis in its Interpretation and Application Guidance: obliged entities decide on their own responsibility on the type, scope, and timing of the training. This guidance does not name an interval either (section 3.6); training at least annually is, in our assessment, common practice but is not prescribed in the guidance. According to it, in principle all employees must be trained – BaFin draws a limit at most for activities with no connection whatsoever to the tasks typical of the business.

According to BaFin, occasion-related circumstances must be taken into account in the timing and design of the training, such as new statutory rules, significant changes in BaFin's administrative practice, findings on new forms of money laundering, new employees joining, and the frequency of incidents relevant under anti-money laundering law or increased error rates.

Limit/exception: "At least annually" is neither statutory wording nor a requirement of BaFin's guidance but, in our assessment, common practice; which interval is appropriate is decided by the obliged entity on a risk-based basis, and the decision should be documented (our own assessment, supported by BaFin's risk-based line; not statutory wording).

What content must anti-money laundering training cover?

The training must cover at least typologies and current methods of money laundering and terrorist financing, the relevant statutory regulations and obligations, and data protection requirements. This follows directly from the wording of Section 6 (2) no. 6 GwG, which expressly orders the training "including data protection provisions".

In practical terms, this means: employees must know and be able to classify the due diligence obligations relevant to their function (identification, suspicious activity reporting under Section 43 GwG, record-keeping obligations). The depth of content may be graduated by function on a risk-based basis. Which anomalies employees should recognize is shown in the overview of money laundering red flags.

Limit/exception: A mere acknowledgment of receipt without any traceable transfer of knowledge regularly does not satisfy the training obligation; what matters is the verifiable, function-appropriate transfer of the content.

Who is responsible? AML officer and obligation to provide proof

For certain obliged entities – including credit and financial services institutions, payment and e-money institutions, and other groups named in Section 2 (1) nos. 1 to 3, 6, 7, 9, and 15 GwG – the appointment of an AML officer at management level, together with a deputy, is mandatory under Section 7 GwG ; the appointment must be notified to the supervisory authority in advance. In practice, the AML officer is responsible for the design, delivery, and documentation of the training. Where there is no obligation to appoint one, the training obligation remains with senior management.

Training must be documented in a traceable way as an internal safeguard – for example the group of participants, content, date, and format. Only documented training can be proven to the supervisory authority; in the event of an audit, the competent authority can demand corresponding proof.

Limit/exception: Whether an AML officer must be appointed in the individual case depends on the group of obliged entities; the supervisory authority can order the appointment or declare it unnecessary for certain groups.

Which format? Decision tree for classroom training or e-learning

Classroom training and e-learning are permissible: training can be delivered through classroom training or through IT-based training programs or training materials that are appropriate in content and up to date (BaFin guidance, section 3.6). The choice must be made on a risk-based basis and in a verifiable way. The comparison E-learning vs. classroom for GwG training goes into more detail on when which format fits.

• Many employees with similar exposure, standardized content, need for proof? E-learning with learning assessment and automatic documentation.
• Complex case constellations, high-risk functions? In-depth formats with casework – for example scenario-based e-learning modules for the functions concerned, live online training, or classroom workshops to discuss specific cases.
• Dispersed sites, different function profiles? Blended learning: a uniform e-learning module for everyone plus function-specific deepening – digital or in the classroom – so that content and proof remain comparable across all sites.
• Event-driven change (new law, new typology)? Short update module in addition to the regular instruction.

Limit/exception: Outdated IT programs or those with no recognizable connection to the employees' functions do not meet the requirement "appropriate in content and up to date"; what matters is not the format but timeliness, relevance to the function, and documentation of delivery.

What does a violation cost? Range of fines under Section 56 GwG

Violations of internal safeguards under Section 6 GwG can be punished as an administrative offense under Section 56 GwG . In the standard range, fines of up to 150,000 euros for intentional violations and up to 100,000 euros for reckless (leichtfertig) violations may be imposed (Section 56 (1) GwG); this offence does not cover simple negligence. For certain serious or repeated violations, Section 56 GwG provides for significantly higher ranges.

Specifically, Section 56 (3) GwG extends the range for serious, repeated, or systematic violations: the fine can reach up to one million euros or up to twice the economic benefit derived from the violation; for certain obliged entities in the financial sector (Section 2 (1) nos. 1 to 3 and 6 to 9 GwG), fines of up to the higher of five million euros or ten percent of annual total turnover are possible.

In addition to the fine, there is a reputational risk: under Section 57 GwG, the competent supervisory authority in principle publishes final measures and incontestable decisions imposing fines; the publication as a rule remains accessible on the authority's website for five years. Only in the exceptional cases provided for by law is it anonymized or delayed. Missing or inadequate training can also feed into further proceedings as organizational fault.

Limit/exception: The specific amount of the fine depends on the severity, intent, and group of obliged entities; the amounts mentioned are the standard range of individual offenses, not in every case the upper limit. The assessment in the individual case is the responsibility of the competent authority.

Outlook: what does the EU Anti-Money Laundering Regulation (AMLR) change from 2027?

Until the EU Anti-Money Laundering Regulation (AMLR, Regulation (EU) 2024/1624) applies on July 10, 2027, the GwG continues to apply. Until then, Section 6 GwG remains the authoritative basis of the training obligation; there is a dual regime of the national GwG and an EU framework that is taking shape.

The EU Anti-Money Laundering Authority AMLA (Regulation (EU) 2024/1620), based in Frankfurt am Main, already began its work on July 1, 2025; according to current planning, direct supervision of selected obliged entities is to begin from 2028. From July 10, 2027, the AMLR will become directly applicable law and replace key GwG requirements. Instruction and training of employees remain mandatory in principle. The Regulation governs training itself: under Art. 12 AMLR, obliged entities must take measures so that employees whose function so requires know the requirements; this includes participation in specific, ongoing training programmes, which must be appropriate to function and risk and must be documented.

Limit/exception (as of 28 May 2026): Detailed rules and AMLA Level 2 standards are in part not yet final. How supervisory practice will specifically fill in these requirements is currently open; companies should follow developments until the cut-off date.

Methodology & timeliness

This article is based on primary sources: the wording of Sections 2, 4, 6, 7, 43, 50, 56, and 57 GwG (gesetze-im-internet.de), BaFin's Interpretation and Application Guidance on the GwG (as of July 2025), and the EU Anti-Money Laundering Regulation (EU) 2024/1624 and the AMLA Regulation (EU) 2024/1620 (EUR-Lex). Statements on training "at least annually" are labeled as our own assessment of practice, not as statutory wording and not as a requirement of BaFin's guidance. Research as of 14 Oct 2026.

Is GwG training mandatory by law?

Yes. Under Section 6 (2) no. 6 GwG, obliged entities under Section 2 GwG must provide their employees with initial and ongoing training on methods of money laundering and terrorist financing and on the relevant obligations. For real estate agents and traders in goods, this applies only to the transactions and thresholds named in Section 4 (4) and (5) GwG. Training is an internal safeguard and therefore an organizational obligation, not a voluntary offering.

How often must anti-money laundering training take place?

The GwG does not name a fixed frequency but requires ongoing training. BaFin allows the type, scope, and timing to be determined on a risk-based basis. Training at least annually is, in our assessment, common practice but is prescribed neither in the law nor in BaFin's guidance. Occasions such as legislative changes or new typologies must be taken into account in the timing of the training.

Who is an obliged entity under the GwG?

Obliged entities under Section 2 GwG include credit institutions, financial services providers, insurance undertakings and intermediaries, traders in goods, real estate agents, as well as lawyers and tax advisers. What matters is the activity carried out, not the industry designation. Only those who fall under this catalog are subject to the training obligation under Section 6 GwG.

What content must GwG training cover?

Under Section 6 (2) no. 6 GwG, mandatory content comprises typologies and current methods of money laundering and terrorist financing, the relevant regulations and obligations, and data protection requirements. In practice, this includes due diligence obligations, suspicious activity reports, and record-keeping obligations. Depth and focus may be graduated by function on a risk-based basis.

What fine may be imposed if training is missing?

Violations of internal safeguards under Section 6 GwG can be punished as an administrative offense under Section 56 GwG, in the standard range with up to 150,000 euros for intent and up to 100,000 euros for recklessness (Leichtfertigkeit). Higher ranges apply to certain serious or repeated violations. The competent authority determines the specific amount according to severity and culpability.

Is e-learning permissible for GwG training?

Yes. Training can be delivered through classroom training or through IT-based training programs or training materials that are appropriate in content and up to date. What matters is not the format but timeliness, relevance to the function, and verifiable transfer of the content. E-learning with learning assessment and documentation is particularly suitable for large groups of employees with similar exposure.

• Section 6 GwG – Internal safeguards (training of employees), gesetze-im-internet.de – accessed 14 Oct 2026
• Section 2 GwG – Obliged entities – accessed 14 Oct 2026
• Section 4 GwG – Risk management (thresholds for real estate agents and traders in goods) – accessed 14 Oct 2026
• Section 7 GwG – AML officer – accessed 14 Oct 2026
• Section 43 GwG – Reporting obligation (suspicious activity report to the FIU) – accessed 14 Oct 2026
• Section 50 GwG – Competent supervisory authority – accessed 14 Oct 2026
• Section 56 GwG – Administrative fine provisions – accessed 14 Oct 2026
• Section 57 GwG – Publication of final measures and incontestable decisions imposing fines – accessed 14 Oct 2026
• BaFin – Interpretation and Application Guidance on the GwG (as of July 2025) – accessed 14 Oct 2026
• Regulation (EU) 2024/1624 (AMLR), Art. 12 (training programmes), applicable from 10 Jul 2027, EUR-Lex – as of 14 Oct 2026
• Regulation (EU) 2024/1620 (AMLA Establishing Regulation), AMLA Frankfurt operational since 1 Jul 2025, EUR-Lex – accessed 28 May 2026