Important Updates on Anti-Money Laundering: What Law Firms Need to Know Now

Commencement of the EU Anti-Money Laundering Authority (AMLA)

A historic step: As of 1 July 2025, the new European AMLA (Anti Money Laundering Authority) has commenced operations in Frankfurt am Main. Its central aim is to harmonise and enhance anti-money laundering prevention within the EU. There is good news for the legal profession: The Federal Bar Association (BRAK) has dispatched representatives, Laura Funke and Dr. Emanuel H. F. Ballo, to the AMLA expert network. This hopefully ensures that the specific concerns of lawyers are adequately considered at the European level.

Updated Risk Analysis Templates from BRAK

An important tool for law firms: BRAK has published updated risk analysis templates in July. These greatly facilitate the creation of the legally required risk analysis. What is particularly noteworthy is that the new templates dynamically refer to the current FATF and EU lists. This means for you: Your risk analysis remains automatically up-to-date, even if the relevant lists change. This saves manual effort and simultaneously increases the security of your compliance processes.

New EU High-Risk Countries List

The EU Commission has issued an updated list of high-risk third countries. Newly listed are Algeria, Angola, Côte d'Ivoire, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal and Venezuela. Meanwhile, Barbados, Gibraltar, Jamaica, Panama, the Philippines, Senegal, Uganda, and the United Arab Emirates have been removed. For business relationships with individuals from the newly listed countries, enhanced due diligence obligations under Section 15(5) GwG now apply. A careful examination of identity, beneficial ownership, transaction purpose, and the origin of funds is essential.

Technical Innovation: Two-Factor Authentication for goAML

As of 1 September 2025, the FIU will introduce two-factor authentication (2FA) for the goAML reporting portal. Users will receive a six-digit code via email after logging in, which must be entered additionally. Please ensure that your internal email addresses and user management are timely adjusted to ensure seamless access.

Conclusion

The recent developments emphasise the necessity to continuously review and adapt compliance processes. The new AMLA, updated BRAK templates, and the heightened obligations for business relationships with high-risk countries demand constant vigilance. With the right digital solutions and a keen eye on current developments, law firms can not only remain compliant but also boost their efficiency and focus on their core tasks.