Apply for exemption from the obligation to appoint an anti-money laundering officer

As a financial company, you are obliged to appoint an anti-money laundering officer and a deputy.

Goods traders who trade in high-value goods may be obliged to appoint an anti-money laundering officer by general decree in some federal states.

Under certain conditions, they can be exempted from the obligation to appoint an anti-money laundering officer upon application. It must be ensured that all obligations specified in the Money Laundering Act are complied with even without an anti-money laundering officer.

This includes that you, as an obliged party under the Money Laundering Act, prove that

• all relevant areas of your company are provided with the necessary information to prevent money laundering and that there is no risk of information being lost, especially in the case of a division of labour structure
• following a risk-based assessment, other precautions are taken to prevent business relationships and transactions associated with money laundering or terrorist financing.

Both requirements must be met.