Organisational measures

In addition to the already-mentioned due diligence obligations set out under Art. 3 – 7 GwG (identification etc.), a financial intermediary must implement the measures which are necessary in his sector to effectively prevent money laundering and terrorism finance in his field of activity. This encompasses in particular the obligation to provide in-house employees with adequate training and to introduce or to conduct regular checks.

The individual regulations of the self-regulating organisations detail the organisational measures used to prevent money laundering inter alia as follows:

  • obligation to carefully select, instruct and check the persons active in the GwG field
  • appointment of managers and deputies in the GwG-relevant field
  • obligation to provide personnel in the GwG-relevant field with training and further training
  • drawing up of internal guidelines
  • creation of a specialist internal department (from a certain size onwards)

In other respects, a financial intermediary may delegate due diligence obligations by engaging another financial intermediary (selection, instruction, monitoring). This is conditional upon the latter individual being subject to comparable supervision from a technical GwG perspective