Terrorist financing; implementation of supervision

The Act on the Tracing of Profits from Serious Crimes prescribes security measures and due diligence requirements for the performance of certain activities. The Act on the Detection of Profits from Serious Crimes prescribes security measures and due diligence requirements for the performance of certain activities. This is intended to prevent the misuse of the economy for the purpose of money laundering and terrorism financing.


The Money Laundering Act (AMLA), which was originally specifically designed to combat organized crime, was expanded under the impact of the terrorist attack on the World Trade Center in New York on September 11, 2001, to counter the threat of international terrorism.

What is terrorist financing and how can it be identified?

A legal definition of the term terrorist financing is provided by Section 1 (2) of the Act on the Tracing of Profits from Serious Crimes (Money Laundering Act - AMLA):

"Terrorist financing within the meaning of this Act is

  1. the provision or collection of property with the knowledge or intention that such property will be used or is intended to be used, in whole or in part, to commit one or more of the following criminal acts:
    • An act under Section 129a of the Criminal Code, also in conjunction with Section 129b of the Criminal Code; or
    • another of the offenses circumscribed in Articles 3, 5 to 10 and 12 of Directive (EU) 2017/541 of the European Parliament and of the Council of 15 March 2017 on combating terrorism and replacing Council Framework Decision 2002/475/JHA and amending Council Decision 2005/671/JHA (OJ L 88, 31.03.2017, p. 6),
  2. the commission of an act pursuant to Section 89c of the Criminal Code, or
  3. the instigation of or aiding and abetting of an act referred to in point 1 or 2."

The European Union has created a dedicated page on combating the financing of terrorism. The Internet site also contains a tool for identifying persons, groups and entities that are subject to a comprehensive ban on disposal as a result of a sanction (see "Related Links"). If a sanctioned person, group or organization is involved in a transaction offered to you, this will generally trigger the fulfillment of the general due diligence obligations pursuant to Section 10 (3) No. 3 AMLA and the filing of a SAR pursuant to Section 43 (1) No. 2 AMLA (see "Money Laundering; Filing a SAR" under "Related Topics"). Among others, the following indicators may point to possible terrorist financing:

  • Hits in "Terror List": The German Federal Office of Economics and Export Control (BAFA) has published a "Fact Sheet on Country-Independent Embargo Measures to Combat Terrorism," which contains recommendations for action in dealing with sanctions lists as well as other informative tips. The sanctions lists (national, EU or UN) are freely accessible on the Internet (see: further links)
  • conspicuous change of character of the customer (e.g. change of clothing - away from Western European outfit;
  • transactions always below threshold amounts and in cash;
  • conspicuous avoidance of personal contact by the customer;
  • frequent presentation of conspicuously new identification documents;
  • refraining from the transaction if further information is required;
  • Indications of support for persons/groups that are to be regarded as fundamentalist/extremist (e.g., in constitutional protection reports);

For further information on this topic, see also "Further links "For further information on this topic, see "Money Laundering; Implementation of Supervision" and "Money Laundering; Filing a Suspicious Activity Report" under "Related Topics".

Competent supervisory authority for

  • Financial companies (Section 2 (1) No. 6 AMLA in conjunction with Section 1 (24) Sentence 1 AMLA)
  • Insurance intermediaries (Section 2 (1) No. 8 AMLA)
  • Non-chambered legal advisors and registered persons pursuant to Section 10 of the Legal Services Act (Section 2 (1) No. 11 AMLA)
  • Service providers for companies and trust assets or trustees (Section 2 (1) No. 13 AMLA)
  • Real estate agents (Section 2 (1) No. 14 GwG)
  • dealers in goods and art brokers (Section 2 (1) No. 16 GwG)

is the Government of Middle Franconia for the administrative districts of Upper, Lower and Middle Franconia, Swabia and the Upper Palatinate, and the Government of Lower Bavaria for the administrative districts of Upper and Lower Bavaria (Section 50 No. 9 AMLA in conjunction with Section 8a Zuständigkeitsverordnung - ZustV).


Responsible for editing:Bayerisches Staatsministerium des Innern, für Sport und Integration

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