GwG training is mandatory for all obliged entities under Section 2 of the German Money Laundering Act (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: 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.
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 custodians – 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 "at least annually" expectation described below stems primarily from the supervisory practice of the financial sector; in the non-financial sector, the standard must be aligned on a risk-based basis with the respective competent supervisory authority.
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. In supervisory and audit practice, training of the relevant employees at least annually is considered the customary standard.
According to BaFin, occasions that trigger training beyond the annual interval include legislative changes, significant changes in BaFin's administrative practice, new money laundering typologies, and new employees joining.
Limit/exception: "At least annually" is not statutory wording but a supervisory and practical expectation; with a low risk profile, a different interval may be justifiable but must be justified and documented (assessment based on common practice, supported by BaFin's risk-based line; not statutory wording).
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.
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.
Both formats are permissible: training can be delivered through classroom training or through IT-based training programs that are suitable in content and up to date. 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.
Limit/exception: Outdated IT programs or those with no recognizable connection to the employees' functions do not meet the requirement "suitable in content and up to date"; what matters is not the format but timeliness, relevance to the function, and documentation of delivery.
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 other violations may be imposed. 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 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.
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.
Limit/exception (as of 28 May 2026): Detailed rules and AMLA Level 2 standards are in part not yet final; specific training requirements under the AMLR are subject to future specification. How supervisory practice will specifically fill in these requirements is currently open; companies should follow developments until the cut-off date.
This article is based on primary sources: the wording of Sections 2, 6, 7, 43, 50, 56, and 57 GwG (gesetze-im-internet.de), BaFin's Interpretation and Application Guidance on the GwG (as of 29 Nov 2024, supplemented on 6 Mar 2025), and the EU Anti-Money Laundering Regulation (EU) 2024/1624 and the AMLA Regulation (EU) 2024/1620 (EUR-Lex). Statements on the "at least annual" practice are labeled as a supervisory and practical expectation, not as statutory wording. Research as of 28 May 2026.
Yes. Section 6 (2) no. 6 GwG requires all obliged entities under Section 2 GwG to provide their employees with initial and ongoing training on methods of money laundering and terrorist financing and on the relevant obligations. Training is an internal safeguard and therefore an organizational obligation, not a voluntary offering.
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. In supervisory and audit practice, training at least annually is considered the customary standard. Occasions such as legislative changes or new typologies can trigger additional training.
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.
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.
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 in other cases. Higher ranges apply to certain serious or repeated violations. The competent authority determines the specific amount according to severity and culpability.
Yes. Training can be delivered through classroom training or through IT-based training programs that are suitable 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.
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