Deutsche Bank: BaFin Sets New Deadlines
BaFin, Germany’s Federal Financial Supervisory Authority, has set new deadlines for Deutsche Bank AG to remedy shortcomings in the data processing systems it uses to monitor transactions for money laundering and terrorist financing. The order is dated 15 September 2026 and became final and binding, meaning no longer open to appeal, on Tuesday 6 October. BaFin published its notice today, 9 October 2026. The notice mentions no fine or other penalty.
BaFin issued the order under section 51(2) sentence 1 of the GwG (Geldwäschegesetz, the German Money Laundering Act), read with section 25h(5) of the KWG (Kreditwesengesetz, the German Banking Act). Those provisions sit alongside the underlying duties: section 25h(1) to (3) KWG, section 6(2) no. 1(e) GwG and section 10(1) no. 5 GwG. Credit institutions must run systems that screen payments for suspicious activity, a process known as transaction monitoring, and report suspicious cases to the FIU, the Financial Intelligence Unit, which is the state body that receives suspicious-activity reports. BaFin states that “these systems must be continuously updated to ensure their reliability.”
The notice does not describe the original shortcomings and gives no new dates. It does say why the deadlines moved. In BaFin’s words, “the order of 15 September 2026 updates these earlier orders, as a reorganisation of the bank’s transaction monitoring system due to changes in technical requirements necessitated new deadlines for remedying the shortcomings in some cases.” According to the notice, then, new deadlines were needed in some cases. The notice cites three orders, dated April 2021, November 2023 and 15 September 2026.
Read cautiously, the notice suggests that a change in technical requirements, such as a reorganised monitoring system, was the stated reason for new deadlines, and that the notice presents the duty to keep systems up to date as continuing. It does not say how BaFin handles such cases more generally.
