In their statement on the government draft for the implementation of the 5th EU Money Laundering Directive, Deutsche Aktieninstitut and the Federation of German Industries (BDI) demand to avoid additional legal uncertainty and unnecessary bureaucracy for goods traders. The two associations criticise the fact that in many places the regulations have been significantly tightened beyond the EU requirements.
Commenting on the proposal for a law implementing the 5th EU Money Laundering Directive, Deutsches Aktieninstitut and Bundesverband der Deutschen Industrie ask to avoid higher legal uncertainty and bureaucracy for industrial companies. They name several topcis, for which the German legislator proposes far stricter rules compared to the EU provisions.
In a letter to BMF, Deutsches Aktieninstitut identifies issues, which should be considered in the upcoming national implementation of the 5th EU Anti-Money Laundering Directive. Industrial holdings should be excluded from the obliged parties under § 2 GwG. The same is true for in-house lawyers in companies. Further topics are the practical relevance of the transparency register as well as the supervisory work by the regional councils.
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