Crypto Wallet Providers

On 14 November 2019, the German legislator passed the implementation law (Umsetzungsgesetz) to transpose the amending directive (Änderungsrichtlinie) to the Fourth EU Anti-Money Laundering Directive 2018/843, which has been the subject of intense debate in recent months and which entered into force on 1 January 2020. The implementation act contains numerous gold plating amendments, particularly in relation to so-called cryptographic values.

Germany is obliged to implement the 5MLD by 10 January 2020. The recently published Draft now provides changes that comply with the requirements of 5MLD and - in line with the typical German gold-plating approach - partially go beyond the European regulatory framework. The Draft mainly concerns amendments to the Anti-Money Laundering Act (Geldwäschegesetz – "GwG"), but also (complementary) amendments to the German Banking Act (Kreditwesengesetz – "KWG").