Comments
19th of May 2025

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

and the form of reporting within the meaning of section 45 (5) sentence 1

German Banking Industry Committee Legal affairs
Sandro Hartmann
Sandro Hartmann

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.

DK Stellungnahme GWG Meldeverordnung

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Sandro Hartmann

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Sandro Hartmann

Legal Affairs and Anti-money Laundering

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Comments
15th of July 2026

GBIC comments on the EBA Discussion paper

Simplification and assessment of the credit risk framework

The German Banking Industry Committee welcomes the initiative of the European Banking Authority (EBA) to explore possible avenues for simplifying the existing credit risk framework.