Anti-Money Laundering for Goods Dealers & the Car Trade
Anyone who trades in goods commercially is an obliged entity under the German Anti-Money Laundering Act (Section 2(1) No. 16 GwG). However, many obligations only apply when cash is involved – and that is exactly where money launderers strike. Car dealerships and dealers in luxury goods, boats or construction machinery are particularly affected.
Which obligations apply when?
| Situation | Obligations |
|---|---|
| Cash payment of €10,000 or more (including several linked payments) | General due diligence (identification, beneficial owner, PEP check) and effective risk management |
| Cash payment of €2,000 or more when trading in precious metals such as gold, silver and platinum | Due diligence and risk management from this lower threshold |
| Suspicion of money laundering or terrorist financing | Due diligence regardless of amount and payment method and, where applicable, a suspicious activity report to the FIU |
Outlook 2027: Under the EU Anti-Money Laundering Regulation (AMLR), an EU-wide limit of €10,000 for cash payments in the trade of goods and services applies from 10 July 2027. For dealers in certain high-value goods, identification obligations are also planned from €3,000 in cash. Now is a good time to prepare your processes.
Typical warning signs
- The customer insists on paying large amounts in cash without a plausible reason
- Payment by third parties or cash delivered by other persons
- Splitting payments just below thresholds
- Purchase contract in one person's name, use or registration by another
- Short-notice cancellation with a request for repayment by bank transfer
- Links to high-risk countries or sanctioned persons
Our support
- Checking whether and from when the GwG obligations apply to your business model
- Risk assessment and work instructions for sales and the cash desk
- Simple forms for identification and documentation
- Training for the sales team and accounting
- Appointment of an (external) AML officer if ordered by the supervisory authority
Cash in your sales?
Together we check which obligations apply to you and set up lean processes.
Book a no-obligation initial consultationYour contact person
Alen Gruber
Certified Corporate Compliance Specialist
External AML Officer