Money laundering: Traders must register

Anti-money laundering measures: By 2027 at the latest, all goods traders must be registered in the "goAML" reporting portal. Failure to register may soon be punishable as an administrative offense.

Classic cars, expensive watches, antiques – some luxury goods are suspected of being used for money laundering. Companies offering such products, just like banks, lawyers, or real estate agents, are obligated to prevent money laundering. Since January 1, 2024, registration in the electronic reporting portal "goAML Web" of the Financial Intelligence Unit (FIU) has been mandatory. For most other goods traders, the registration requirement applies from January 1, 2027. However, they can register before then. The aim is to enable the rapid submission of suspicious activity reports via the portal.

Anyone dealing in art, jewelry, watches, precious metals, gemstones, motor vehicles, ships, or motorboats must already be registered. However, a transitional regulation is currently in effect , according to which non-registration does not constitute an administrative offense for these goods dealers.

The German government is now planning to introduce a new administrative offense , making the failure to register with the FIU's "goAML" suspicious activity reporting portal a punishable administrative offense. The German Chamber of Public Accountants (WPK) drew attention to this in August 2026. According to the WPK, the German government plans to make the failure to register with the FIU's "goAML" suspicious activity reporting portal a punishable administrative offense.

Companies obliged to prevent money laundering must, by law,

• Due diligence obligations regarding their clients,
• Risk Management operate and
• If money laundering is suspected, the FIU can file a complaint via the electronic reporting portal Submit a report.

The individuals and companies required to cooperate are also referred to as "obligated parties" in official terminology . Such a suspicious activity report can only be submitted after prior registration with the FIU.

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Incidentally, the obligation to report suspected cases applies regardless of the transaction amount (for goods traders, this also applies even if the threshold of €10.000 is not reached) and the payment method (cash or cashless), customs officials emphasize. Anyone who suspects something is amiss must report their suspicion electronically, even below this amount.

Who is affected?

The Money Laundering Act applies to banks and investment companies, but also to companies outside the financial sector. Even traders in goods are required to register.  

Goods within the meaning of the Money Laundering Act are defined in the Money Laundering Act as items,

• which, due to their nature, their market value or their intended use, stand out from everyday objects or
• which, due to their price, are not an everyday purchase.

These currently include, among others:

• Gold, silver and platinum,
• Copper and rare earths
• gemstones,
• Jewelry and watches,
• Art objects and antiques,
• Motor vehicles,
• Ships and motorboats
• and aircraft.
  
  

From 2027 onwards, all goods traders will have to register.

Registration can be completed via the FIU homepage in the goAML WEB portal.

Source: ZDH; DHB; WPK

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