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Outsourcing MLRO in Germany

Outsourcing MLRO in Germany inquire online: HIT THE GROUND RUNNING IN GERMANY – OUTSOURCE YOUR MLRO in Germany

We offer competitive outsourcing packages for companies, asset managers and banks seeking outsourcing solutions in Germany. In Germany it is a requirement by law to have one MLRO (Money Laundering Reporting Officer) and one deputy MLRO. Our target is to establish for you a tailored audit-proof risk management for the prevention of risk management and CFT. Our outsourcing arrangements include the following:

  • Appointment as Money Laundering Reporting Officer (and Deputy MLRO) in Germany, if required
  • In this function we monitor your business in accordance to the German MLA (and guidelines to the German MLA) as well as other legal requirements, as applicable.
  • Advise and inform the management on existing obligations for the prevention of money laundering and TF
  • Assume responsibility to communicate with supervisory authorities.
  • Selected processes (as agreed with you) are monitored on a random basis, risk-oriented and in agreed frequencies for your compliance department.
  • As specialists with existing UK mandates, we can hit the ground running and only require your company specific information. As set out in the law, we report directly to the management.

Please send us a mail to receive a free quote „Outsourcing MLRO“.

S+P Prevention of Money Laundering Compliance Team – Inquire now online: to receive a free quote.


Outsourcing MLRO in Germany


S+P Team -Prevention Money Laundering  – Outsourcing MLRO in Germany

Introduction of the S+P Prevention Money Laundering Team specialised in Outsourcing MLRO in Germany

Achim Schulz has been advising medium-sized companies and banks for 22 years. His areas of expertise include CRR institutes, acquirers, fintech, capital management companies, leasing and factoring companies and medium-sized companies.

He advises companies on the implementation of risk management and compliance systems.


Alexander Schneider has been working for banks, financial service providers, insurance companies and medium-sized companies for more than 20 years.

As a compliance and money laundering officer, Alex advises companies on the implementation of money laundering compliance standards.


Lawyer Alexander Suck is an experienced expert with focus on corporate and criminal law. Together with his legal team, he advises medium-sized companies on the implementation of legal obligations for the prevention money laundering and CFT. He develops risk mitigation strategies for compliance and Money Laundering Reporting Officers.


Miriam Boglino has been working for asset managers in the UK for over 11 years. Her last position was as Senior Legal Adviser.  She is very familiar with the UK asset managers and their processes and the administration in Luxembourg and Dublin. Since February 2017 she is the outsourced MLRO for a UK asset manager. In Germany she advises medium-sized companies to set up and improve existing European compliance management systems.


Outsourcing officers – Outsourcing with S+P Outsourcing Solutions in Germany.

What outsourcing solutions do we offer?

We offer Outsourcing Solutions for MLRO in GermanyData Protection Officer, Information Security Officer, Compliance Officer or Internal Audit. You can see the scope of the task covered by our S & P Compliance Team directly in the following performance overview.


Ensuring the required compliance for the prevention of money laundering

To ensure the required compliance systems and processes are in place for the prevention of money laundering and CFT we have summarised for you the 16 legal obligations that need to be implemented within a MLRO outsourcing solution:

Implementation and supervision of all regulations for the prevention of money laundering and terrorist financing (AML/CFT)

  1. Contact person for BaFin, FIU and law enforcement agencies
  2. Establish adequate risk management systems and processes including clear reporting requirements
  3. Tailored company specific risk assessment
  4. Development and updating of internal principles, appropriate business and customer-related security systems
  5. Implementation of ongoing risk-oriented, process-accompanying or at least timely monitoring, inspection and control measures
  6. Continuous development of strategies and safeguards
  7. Operation and updating of adequate data processing systems
  8. Investigation of unusual or doubtful facts
  9. Handling of suspicious cases including the submission of suspicious transaction reports
  10. Decision about the termination of the business relationship with the involvement of the management
  11. Information to management and the supervisory body: Measures taken in particular concerning the deficits of the prevention measures and to remedy deficits, preparation of an at least annual report on activities and the risk situation of the company, if necessary, in the context of the risk analysis as well as ad hoc reports in the presence of special causes,
  12. The Board shall forward the report to the Chairman of the Board of Supervisors, with reference to any material deviations from the assessments made by the Money Laundering Reporting Officer. For its part, the chairman of the supervisory body has rights of access directly to the Money Laundering Reporting Officer.
  13. Providing training and ongoing information to employees about new methods of money laundering and terrorist financing as well as new legal and regulatory requirements.
  14. Advising and supporting employees and businesses in complying with anti-money laundering and terrorist financing legislation (AML/CFT).
  15. Advise on the improvement and adjustment on applicable organisational and clear task definitions and instructions.


Even non-financial companies need a money laundering prevention system – Outsourcing MLRO in Germany

The German Money Laundering Act is aimed not only at companies in the financial sector, such as banks or corporations, but also at companies outside the financial sector.

Among others, the German Money Laundering Act applies to the following non-financial companies:

  • Goods traders (any person who sells commercial goods, regardless of in whose name or on whose behalf it trades),
  • Legal service providers (non-licensed legal assistants and registered persons according to § 10 of the Legal Services Act, if they plan and perform certain business for clients),
  • Service providers for companies and trusts or trustees when providing certain services (e.g. offering shelf companies),
  • Real estate agents is any persons who commercially arranges the purchase or sale of land or rights equivalent to real estate,
  • Organiser and broker of games.

In order to prevent money laundering, companies must obtain and document information about the identity of their contractual partners, who may be responsible for this person and the beneficial owner (know your customer principle – know your customer). They need to monitor their business relationships for abnormalities and take internal safeguards to detect money laundering leads.

For this purpose, a risk management system according to para 4  German MLA includes a  risk analysis  and para 5 German MLA as well as internal security measures according to para 6 German MLA must be set up.

Outsourcing the Money Laundering Reporting Officer (Outsourcing MLRO): Please send us a mail to receive a free quote „Outsourcing MLRO“.

Mail: S+P Prevention of Money Laundering Compliance Team to receive a free quote.


Governance Outsourcing: Supervisory Rules and requirements

BaFin requirements: All undertakings are allowed to outsource functions. In the event of outsourcing, undertakings must ensure compliance with all supervisory rules and requirements. To this end, the undertakings must adopt a written policy for the outsourced functions.

If an undertaking also intends to outsource key tasks – e.g. one of the four key functions – it must designate an „outsourcing officer“ responsible for supervising the outsourcing process. However, the ultimate responsibility of the management board (or other persons appointed to represent the undertaking) for the outsourced function or insurance activity cannot be delegated but always remains within the undertaking.


The most important changes at a glance – German Money Laundering Act

Here you find further information about AML/CFT – German Version and Outsourcing MLRO in Germany: