Money laundering warning signs, known in professional jargon as "red flags", are anomalies in everyday business that may indicate an increased risk of money laundering – no more and no less. They are indicators, not proof: A single signal does not in itself justify suspicion; multiple signals must always be assessed in context. This overview brings together five categories of typical warning signs as known from the typologies of the Financial Intelligence Unit (FIU) and BaFin's interpretation and application guidance. It does not replace a legal case-by-case review under the German Money Laundering Act (GwG). For obliged entities, the patterns are also a practical tool: Those who know them fulfill their due diligence and reporting obligations on a more solid basis and classify anomalies objectively rather than hastily.
Why the patterns matter at all: Since March 18, 2021, the so-called all-crimes approach has applied in Section 261 of the German Criminal Code (StGB) – since then, any unlawful predicate offense can give rise to money laundering, no longer just a narrow catalog of serious criminal offenses. This has significantly broadened the range of suspicious circumstances. Section 43 GwG provides the abstract test: Indicators that trigger a reporting obligation generally exist when assets could originate from an illegal source, there is a link to terrorist financing, or the contracting party does not disclose whether it is acting on behalf of a beneficial owner – regardless of the amount and the method of payment. The specific assessment in the individual case remains reserved for the responsible function. How the money enters the economic cycle in the first place is shown in the overview of the three stages of money laundering; the criminal law basis is explained in the definition of money laundering under Section 261 StGB.
The behavior of the other party is often the first visible signal – and paying attention to it costs nothing. It becomes conspicuous where someone conceals their own role or the origin of the funds instead of making them transparent. This is exactly where the law comes in: If a contracting party cannot or will not disclose whether it is acting on behalf of a beneficial owner, Section 43 GwG expressly names this as an indicator that triggers a reporting obligation.
Typical indicators in this category:
An abstract example: A customer wants to complete a high-value purchase immediately but evades every question about the origin of the funds and names changing persons as the "actual" buyers. No single characteristic proves anything – only the accumulation of several indicators makes the transaction a case for review.
What is conspicuous is what makes no economic sense. If payment routes, amounts, or frequencies do not match the recognizable business purpose, there is a pattern that the FIU regularly describes in its typologies. In 2024, the FIU received 265,708 suspicious activity reports (2023: 322,590); the vast majority come from the financial sector, where transaction data is systematically monitored. The fact that almost all reports come from the financial sector does not mean that the non-financial sector is free of risk – there is often simply no automated monitoring there, so anomalies are less often recorded systematically.
Typical patterns:
Why this is a signal: Structuring deliberately aims to slip below the perception threshold. However, the reporting obligation under Section 43 GwG applies regardless of any amount limit – the splitting itself is the indicator, not the individual partial payment.
Cash remains the central risk area, especially in the non-financial sector. Because cash transactions leave less of a data trail, the anti-money laundering due diligence obligations under Section 10 GwG for traders in goods are specifically geared to cash payments: For high-value goods they apply from 10,000 euros, for precious metals from as little as 2,000 euros. These thresholds trigger due diligence obligations – the obligation to report a suspicion, on the other hand, exists regardless of any amount limit.
This is particularly relevant for traders in goods, car dealers, jewelers, or real estate agents: They are obliged entities under the GwG just like banks, but they monitor transactions automatically less often. At the point of sale, personal attentiveness is therefore the actual control.
Complexity without an economic purpose is rarely a coincidence. Nested constructions often serve to conceal the beneficial owner – that is, the person in whose interest a business relationship is actually maintained. It is precisely this disclosure that Section 43 GwG requires; if it is not made, the indicator has already been named. A practical approach to checking is to compare the information on the beneficial owner with the Transparency Register – if they differ, this is an additional indicator.
An abstract example: A chain of several companies in different countries formally leads to a contracting party who has neither funds nor decision-making authority. Such "facades" are an established typology pattern – not proof of an offense, but a clear trigger for review.
Digital channels extend the known patterns; they do not replace them. In 2024, the FIU recorded 8,711 suspicious activity reports related to crypto assets – a growing segment, but still small in relation to the total volume. BaFin most recently supplemented its interpretation and application guidance on the GwG on March 6, 2025, specifically with crypto-related due diligence obligations.
Why this is a signal: Anonymization is the exception in legitimate transactions and the rule where there is an intent to conceal. The test remains the same as in cash transactions – only the technical packaging is new. Precisely because crypto assets can be transferred across borders and pseudonymously, classic concealment patterns are increasingly shifting to these channels.
The typological warning signs do not exist in a vacuum but within a legal framework that is currently changing. The German Money Laundering Act (GwG) is currently authoritative; it continues to apply until the European Anti-Money Laundering Regulation (AMLR, Regulation (EU) 2024/1624) becomes directly applicable on July 10, 2027. This does not mean a break with the known patterns – on the contrary: The AMLR harmonizes due diligence and reporting obligations across the EU. In addition, the European Anti-Money Laundering Authority AMLA in Frankfurt am Main supervises the new regime; it began its work on July 1, 2025. For practice, this means: The indicators described here remain relevant – the legal framework behind them is merely becoming more uniform.
A warning sign is a trigger for review, not an automatic response. The right way to handle it is risk-based: document anomalies, assess them in context, and – if in doubt – involve the AML officer. Whether and how to respond is governed by the GwG and belongs in the hands of the responsible function, not in a blanket checklist. The report itself goes to the FIU and – this is the practical core of Section 43 GwG – must be submitted regardless of amount and method of payment.
For employees to recognize these patterns in everyday work at all, they must be made aware of them regularly. This is exactly what the law requires: Section 6 (2) no. 6 GwG expressly names the "initial and ongoing training of employees with regard to the typologies and current methods of money laundering" as an internal safeguard. Which training obligations lie behind this and how often training must take place is shown in the article on the GwG training obligation under Section 6 GwG; whether such training is better delivered as e-learning or in person depends on the business. Further basics are collected in the Anti-Money Laundering topic hub.
Not automatically. A warning sign is initially a trigger for review, not a finished suspicion. Whether there is a reporting obligation under Section 43 GwG depends on the individual case and is, as a rule, assessed by the responsible function – for example the AML officer. The report to the FIU is then made regardless of amount and method of payment.
No. In addition to banks, non-financial obliged entities such as traders in goods, real estate agents, car dealers, or jewelers are also bound by the German Money Laundering Act. Especially with cash and high-value goods, they encounter the same patterns – often without automated transaction monitoring, so that personal attentiveness at the point of sale is the decisive control.
They summarize generally established indicators from the typologies of the FIU and BaFin's interpretation and application guidance. They are not an exhaustive official checklist but guidance for everyday business. The binding assessment of a specific set of facts always remains reserved for the responsible function in the company.
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