Germany’s Three-Working-Day AML Rule Does Not Set an Account-Reopening Deadline

Germany’s financial regulator warned Tuesday, Oct. 20, about remote jobs routing third-party payments through personal accounts for crypto conversion; a separate law governs when a reported transaction may proceed.

The Federal Financial Supervisory Authority (BaFin) described offers using the names “KBG Beratung” and “KBG Pro” on kbg-beratung.de. The work involved receiving payments into a personal German bank account, then forwarding the funds or exchanging them for crypto assets. BaFin’s warning identified no operators and described the services as suspected of being unauthorized.

KBG Pro GmbH, based in Stuttgart, had no connection to the website or the offers, BaFin said. The regulator presumed the funds came from third parties who had themselves been victims of criminal acts, particularly fraud; it did not identify the operators.

Section 46 of Germany’s Money Laundering Act sets conditions for when a reported transaction may proceed. It may go ahead if the Financial Intelligence Unit or a prosecutor approves it, or after the third working day following dispatch of the report passes without a prohibition. Saturday does not count as a working day.

That period applies to the reported transaction. It does not set a deadline for a bank to restore access to an entire account, and it does not require the bank to execute the transaction once the period ends. Section 43 separately requires covered entities to report when facts indicate that an asset may come from a predicate crime, regardless of the asset’s value or transaction amount.

BaFin issued a similar warning in June 2022 about a home-office “Crypto Assistant” offer involving third-party payments routed through a personal bank account for forwarding or conversion into crypto. The earlier alert shows the practice had drawn regulatory attention before, but does not establish the scale of the current case.