Alexander Cappel

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On 11 December 2018, the German Financial Supervisory Authority (BaFin) published its Guidance Notes on the German Money Laundering Act (Auslegungs- und Anwendungs­hinweise zum Geldwäschegesetz – Guidance Notes). I. Legal basis Pursuant to the German Money Laundering Act (GwG), BaFin has to provide obliged entities belonging to the financial sector with (regularly updated) interpretation and application notes for the implementation of the due diligence and internal safeguard measures to prevent money laundering. Within their scope of…