Germany: New Reporting Procedure Regarding the Appointment or Dismissal of the Money Laundering Officer and Deputy 

On 13 June 2025, the German Financial Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht – “BaFin”) published the launch of a new specialised procedure concerning the prior notification of the appointment, change and dismissal of the money laundering officer (Geldwäschebeauftragter) and its deputy in accordance with Section 7(4) of the German Money Laundering Act (Geldwäschegesetz – “GwG”).

This procedure is now available on BaFin’s reporting and publication platform (Melde- und Veröffentlichungsplattform – “MVP-Portal”) and can be accessed via the BaFin Website. 

Who is affected, and what does this mean? 

This reporting obligation applies to all obliged entities under the GwG that fall under the supervision of BaFin pursuant to Section 50(1) and (2) GwG. 

To clarify, this is not a new reporting obligation for obligated entities; only the process for fulfilling this obligation has changed. Prior notification must now be submitted electronically via the MVP-Portal instead of by email or post, as was previously the case. This digitalisation makes the process faster and easier to verify, resulting in a simpler and more convenient way to comply. 

From 13 June 2025, all obligated entities must fulfil their notification obligations under Section 7(4) GwG via the MVP portal. 

How is it done? 

First, access to the MVP-Portal is required. If an obligated entity does not yet have access, it must complete a registration process for the MVP-Portal. A detailed description of this registration process can be found on the BaFin website here, along with a dedicated user manual by BaFin for the MVP-Portal which can be accessed here.  

In addition to general access to the MVP-Portal, a separate registration for this specific reporting procedure is required. The user manual offers also provides detailed instructions for this step. 

As a final step, BaFin must approve the registration for this reporting. Once approved, the obligated entity can submit related notifications digitally via the MVP-Portal. After submitting a notification, a confirmation is issued, which can be downloaded and printed as a PDF. 

Next Steps 

We recommend that all obligated entities promptly register for this new reporting procedure in the MVP-Portal so that a notification under Section 7(4) of the GwG can be submitted immediately when required. 

How can Zeidler help? 

Zeidler Group is always keen to assist you with any questions or support you may need regarding this new reporting procedure or any other regulatory problems you may encounter. 

Our dedicated team of professionals is well-versed in BaFin reporting requirements and standards. 

If you need further information and assistance on this or any other topic, please do not hesitate to reach out to us.