The FIU is the central agency for the investigation of financial transactions and thus the contact point for reporting suspicions according to the German Money Laundering Act (GwG). On 28 September 2018 it published its annual report for 2017 (http://www.zoll.de/DE/Fachthemen/FIU/fiu_node.html). An examination of the information found in press coverage i.a. on shortcomings of facilities and processing backlog (cf. for instance the article by Spiegel Online dated 28 March 2018 at http://www.spiegel.de/panorama/justiz/lka-thueringen-polizei-empoert-sich-ueber-geldwaesche-einheit-des-zolls-a-1198987.html), however, has not been made.
The report i.a. makes reference to the following issues:
- In the past reporting year 2017, the FIU had to record a continuous increase of incoming notifications of suspicions.
- As far as the allocation with regard to the groups of obligated parties is concerned, there were no fundamental changes. Financial institutions still report most of the suspicious cases, namely over 80%.
- The share of notifications from members of the liberal professions was still low. Merely 23 notifications came from lawyers and two notifications from tax consultants. It remains a matter of interest to what extent this will change upon increasing sensitisation of these groups in connection with the revision of the GwG as of 26 June 2017 and a more intense examination by the professional chambers.
- 66% of the notifications of suspicion received within the area of responsibility of the new FIU had to be forwarded to the prosecution authorities.
Unfortunately, no information can be found on the processing times of the suspicious cases within the “new” FIU which has been affiliated with the General Directorate of Customs since 26 June 2017. This is because information about this would enable a valid assessment whether the touted “filtering function” of the FIU, which is to serve as a relief of the prosecution authorities, also brings about a higher degree of efficiency in the fight against money laundering and terrorism.