“Unsubstantiated” suspicious transaction reports
While financial institutions, on the one hand, are in the process of implementing and preparing to apply the fundamental amendments and changes that will take place in upcoming years by the EU AML Package—entering into force mainly in mid-2027—there are, on the other hand, signs of a relaxation of AML compliance requirements in the US. Meanwhile, the Federal Financial Services Authority (“BaFin”) published a remarkable sanctions decision in a case where a payment institution was penalized for failing to establish and maintain a proper business organization in the area of detection of suspicious transactions. BaFin, the German regulator, argued that…
