Opinion on draft ordinance of the required information of the Anti-Money Laundering Act

The German Banking Industry Committee comments on the draft Regulation on Suspicious Activity Reporting. In view of the fact that technical implementation standards based on the Anti-Money Laundering Regulation (EU) are to be drawn up and submitted to the EU Commission as early as next year, the German Banking Industry does not believe that such short-term national legislation is expedient. The draft contains a large number of regulations that bureaucratize the suspicious activity report procedure.