On 18 November, Client Alert from Dentons says that the 6th AML Directive aims to improve the harmonisation of the criminal liability of money laundering and terrorist financing across 27 Member States.  In doing so, it significantly differs from its predecessors and their implementation in previous German AML legislation which mainly dealt with regulatory issues such as the obligation to conduct KYC checks and to report suspicious transactions.  The Client Alert summarises the key proposals and highlights the gold plating approach taken by the German government and takes a closer look at its regulatory implications on financial services firms and insurance undertakings.  The new law out to achieve a “paradigm shift” in the prosecution of money laundering by abandoning the concept of a catalogue of predicate offences, and the proposed money laundering offence, as a matter of German law, will be able to capture profits derived from any criminal activity.  The Client Alert asserts that prosecuting money laundering will become considerably easier in Germany, and extends the investigative power of prosecutors, by making greater use of online searches as well as surveillance of electronic and telephone communications in the investigation of money laundering.

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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