Unterföhring bei München, 02.09.2026 (PresseBox) - I. Management Summary: BaFin Supervisory Notice 06/2026 (A) on vIBAN structures

1. Initial situation and regulatory core

The supervisory authority points out that significant transparency deficits regarding the actual end customers and beneficial owners can arise, particularly with multi-tiered and cross-border viBAN structures. This can restrict the traceability of payment flows and increase the risk of use for underground banking, money laundering, or other criminal activities (Section 261 of the German Criminal Code; Sections 10 para. 1 nos. 1?5, 11, 15, 43 para. 1 of the German Money Laundering Act).

2. Clarification of the statutory due diligence obligations

BaFin specifies its supervisory expectations regarding the anti-money laundering treatment of vIBAN models. Institutions must examine, within the framework of their risk-based approach, whether and to what extent their risk analysis, due diligence obligations, internal safeguards, and monitoring systems need to be adapted (§§ 4, 5, 6, 10 para. 1 no. 5, 15 GwG; § 25a para. 1 KWG).

General due diligence obligations ( §§ 10 et seq. GwG ): Solely identifying the holder of the master account may be insufficient for viable IBAN structures if this does not allow for an adequate assessment of the users and payment flows behind the individual viBANs. The institution must therefore ensure, in a risk-oriented manner, that sufficient information about the actual end customers, authorized signatories, and beneficial owners is available and verifiable (§ 10 para. 1 nos. 1?4, para. 2 GwG; §§ 11, 12, 13, 15 GwG).

Enhanced due diligence obligations (§ 15 GwG ): Connected payment service providers and the specific vIBAN structures used must be reviewed regularly and on an ad hoc basis. If the institution-specific risk assessment reveals an increased risk, for example due to complex contractual chains, cross-border structures, insufficient transparency, or restricted rights to information, the enhanced due diligence obligations required under § 15 GwG must be applied (§ 5 para. 1, 2 GwG; § 10 para. 2 GwG; § 15 para. 1?4 GwG).

Account retrieval procedure ( § 24c KWG ): The institution must verify which persons and assignments must be recorded in the account retrieval file in accordance with § 24c KWG. It must be ensured that the legally required information, in particular regarding account holders, authorized signatories, and, where applicable, beneficial owners, is stored completely, correctly, and up-to-date (§ 24c para. 1 KWG). Further IBAN, KYC, and transaction data must be stored separately in the designated internal systems (§ 8 paras. 1?4 GwG; § 10 para. 1 no. 5 GwG).

II. Deadlines and key data

Here is an overview of the relevant deadlines:

July 27, 2026 (publication and commencement of supervisory application): From this date, the risks and supervisory expectations described in the supervisory notice must be taken into account when designing institution-specific risk management. Institutions should promptly conduct a documented impact and gap analysis and derive appropriate implementation deadlines for the necessary adjustments to their risk analysis, internal safeguards, and control systems (Section 5, paragraphs 1?4 of the German Money Laundering Act (GwG); Section 6, paragraphs 1 and 2 of the GwG; Section 25a, paragraph 1 of the German Banking Act (KWG)). The supervisory notice does not provide for an explicit transition period.

Ongoing / Immediate (§ 43 para. 1 GwG): Obligation to immediately submit a suspicious activity report to the FIU upon occurrence of the aforementioned risk indicators (e.g. implausible account transactions, lack of transparency regarding the beneficial owner).

Ongoing / Daily Update (§ 24c para. 1 KWG): The account master data required under § 24c KWG must be maintained completely, correctly, and up-to-date in the account retrieval file (§ 24c para. 1 KWG). The further assignments between vIBANs, end customers, beneficial owners, and transactions must be kept traceable in the institution's internal systems in accordance with the anti-money laundering documentation and retention obligations (§ 8 paras. 1?4 GwG; § 10 para. 1 no. 5 GwG).

July 10, 2027 (end of the time limit and start of direct application of the AMLR) : The BaFin supervisory notice is valid until this date. From July 10, 2027, Regulation (EU) 2024/1624 will, in principle, be directly applicable (Article 90 of Regulation (EU) 2024/1624). Institutions should therefore use the implementation of the supervisory notice as preparation for future EU legal requirements.

5 years retention period (§ 8 para. 1, 2 GwG): Statutory period for the retention of all identification data, contracts and transaction documents collected within the scope of the vIBAN due diligence obligations (period begins at the end of the calendar year in which the business relationship ends or the transaction was carried out).

III. Affected persons, roles and assigned duties

1. C-Level / Board of Directors (Managing Directors)

a.) Role: The management bears overall responsibility for proper business organization and for establishing appropriate anti-money laundering prevention, control, and monitoring structures (§ 6 para. 1 GwG; § 25a para. 1 KWG). In the event of culpable organizational or supervisory deficiencies, supervisory, administrative offense, and corporate liability risks may arise under the respective legal provisions (§ 130 OWiG; § 93 para. 1, 2 AktG; § 43 para. 1, 2 GmbHG).

b.) Assigned duties:

aa.) Provision of adequate resources & governance: Management must ensure that the changed control and monitoring processes are adequately equipped in terms of organization, personnel and technology (release of IT and personnel budget).

Standards *:* Section 6 Paragraph 1 GwG (Internal safeguards), Section 25a Paragraph 1 KWG (Special organizational obligations / MaRisk)

bb.) Acceptance of the risk analysis: Approval of the risk analysis updated by the money laundering officer.

Standard *:* Section 5 Paragraph 4 GwG

2. Money Laundering Officer (MLRO) & Deputy

a.) Role: Responsible for the operational implementation and monitoring of all anti-money laundering regulations (§ 7 GwG) and for informing the board of directors.

b.) Assigned duties:

aa.) Updating the risk analysis: The institution-specific risk analysis must be reviewed promptly and on an ad hoc basis to determine whether vIBAN structures exist within the institution's own business model or are used indirectly. If affected, transparency deficits, multi-tiered contract and account structures, cross-border issues, restricted information rights, and risks of underground banking must be appropriately assessed and documented (Section 5, paragraphs 1?4 of the German Money Laundering Act (GwG); Annex 1 and Annex 2 to the GwG).

bb.) Adaptation of transaction monitoring (technical concept): Based on the updated risk analysis, the IT-supported transaction monitoring must be reviewed to determine whether the existing scenarios, thresholds, and data sources adequately capture the specific risks of vIBAN structures. If control gaps are identified, the detection scenarios must be adapted to the risk profile, validated, and regularly reviewed for effectiveness (Section 6 Paragraph 2 No. 2 of the German Money Laundering Act (GwG); Section 10 Paragraph 1 No. 5 of the GwG; Section 25a Paragraph 1 of the German Banking Act (KWG)).

Legal basis: Section 6 Paragraph 2 No. 2 of the Money Laundering Act (GwG) in conjunction with Section 10 Paragraph 1 No. 5 of the Money Laundering Act (GwG) (Continuous monitoring)

cc.) Suspicious activity reporting: If the identified risk indicators reveal facts that meet the requirements of Section 43 Paragraph 1 of the German Money Laundering Act (GwG), a suspicious activity report must be submitted to the Financial Intelligence Unit (FIU) without delay (Section 43 Paragraph 1 GwG). The mere presence of a single risk indicator does not automatically trigger a reporting obligation, but it must be properly investigated, assessed, and comprehensibly documented (Section 8 Paragraphs 1 and 2 GwG; Section 10 Paragraph 1 No. 5 GwG).

Standard: Section 43 Paragraph 1 GwG (Reporting obligation of obliged entities)

3. Compliance Officer (Second Line of Defense / Regulatory Compliance)

a.) Role: Monitoring the institution's compliance with regulations and ensuring its readiness for audits (§ 25a KWG / MaRisk).

b.) Assigned duties:

aa.) Guidelines & Audit: Adaptation of internal guidelines (policies), inclusion of the vIBAN topic in the compliance monitoring plan and preparation for regulatory audits (§ 44 KWG).

bb.) Targeted staff training (together with GwB): Ensure that employees in relevant specialist areas are specifically trained on the new typologies and risk indicators of vIBAN structures.

Standard: Section 6 Paragraph 2 No. 6 GwG (Information for employees)

4. Managers of operational departments (Payments, KYC/Onboarding, IT)

a.) Role: Operational execution at the customer's site and technical provision of the systems.

b.) Assigned duties:

aa.) Extension of due diligence obligations (KYC & beneficial owner verification): In the case of vIBAN models, it must be ensured, based on risk, that in addition to the contractual partner, the users, authorized signatories, and beneficial owners behind the individual vIBANs are known and verifiable to an extent that allows for an appropriate assessment of the business relationship and the transactions processed through it (§ 10 para. 1 nos. 1?5 GwG; §§ 11?13 GwG). An examination solely of the master account holder is insufficient if this fails to identify significant risks and stakeholders (§ 10 para. 2 GwG).

Legal provisions: Section 10 Paragraph 1 Nos. 1?4 of the Money Laundering Act (General due diligence obligations), Section 11 of the Money Laundering Act (Identification)

bb.) Application of enhanced due diligence obligations: The integration of foreign payment service providers and complex or multi-tiered vIBAN structures must be included in the case-by-case assessment as potentially risk-increasing factors (Section 5, paragraphs 1 and 2 of the German Money Laundering Act (GwG); Annex 2 to the GwG). Whether an increased risk exists within the meaning of Section 15 of the GwG must be determined based on all relevant customer, product, country, distribution, and transaction risks and documented in a comprehensible manner (Section 15, paragraphs 1?4 of the GwG; Section 8, paragraph 1 of the GwG).

cc.) Populating the account retrieval file (IT & master data): The information required under Section 24c of the German Banking Act (KWG) must be provided completely, correctly, and up-to-date for the automated account retrieval procedure via suitable interfaces (Section 24c Paragraph 1 KWG). In addition, the institution must ensure a clear and auditable internal assignment between the vIBAN, master account, contractual partner, end customer, and, where applicable, beneficial owner (Section 8 Paragraphs 1?4 of the German Money Laundering Act (GwG); Section 10 Paragraph 1 No. 5 GwG; Section 25a Paragraph 1 KWG).

Standard: Section 24c Paragraph 1 KWG (Automated retrieval of account information)

dd.) System update (IT): Technical implementation of the new detection patterns defined by the GwB in the IT monitoring systems.

IV. Critical points, liability risks

Insufficient consideration of the risks described in the BaFin supervisory notice can have legal and regulatory consequences for credit institutions, payment service providers, and responsible persons (Sections 6, 10, 15, 43, 56 of the German Money Laundering Act (GwG); Sections 25a, 44, 45, 46 of the German Banking Act (KWG)). Whether and to what extent liability or sanctions arise depends on the specific duty violated, the degree of culpability, the organizational structure, and the circumstances of the individual case (Section 10 of the German Administrative Offenses Act (OWiG); Section 276 of the German Civil Code (BGB); Section 93 Paragraph 2 of the German Stock Corporation Act (AktG); Section 43 Paragraph 2 of the German Limited Liability Companies Act (GmbHG)).

1. ) Liability under administrative offense law (fines)

Violations of the Money Laundering Act (§ 56 GwG): Intentional or negligent breaches of the obligations to conduct risk analysis (§ 5 GwG), the general and enhanced due diligence obligations (§§ 10, 15 GwG), or the obligation to submit a suspicious activity report (§ 43 GwG) constitute an administrative offense. Violations of obligations under the Money Laundering Act that are subject to fines can, under the conditions of § 56 GwG, be directed against the institution or against responsible natural persons (§ 56 paras. 1?4 GwG; §§ 30, 130 OWiG). The amount of the potential fine depends in particular on the nature, severity, duration, and systematic nature of the violation, the degree of culpability, the financial capacity, and any economic advantage gained (§ 56 paras. 2?4 GwG; § 17 paras. 3, 4 OWiG). Maximum amounts related to turnover are only considered under the special conditions stipulated by law (§ 56 para. 3 GwG).

Breach of supervisory duty by management (§ 130 OWiG): Under § 130 OWiG, managing directors or other persons with supervisory duties can be held personally liable if they intentionally or negligently fail to take necessary supervisory measures and thereby enable or significantly facilitate business-related offenses (§ 130 para. 1 OWiG). A personal sanction therefore requires a specifically demonstrable breach of supervisory duty and a sufficient connection to the underlying offense (§§ 10, 17, 130 OWiG).

2.) Civil liability of corporate bodies (internal liability)

Due diligence obligations of the managing director (§ 93 para. 2 German Stock Corporation Act (AktG) / § 43 para. 2 German Limited Liability Companies Act (GmbHG)): Managing directors must exercise the due diligence of a prudent and conscientious business manager. Failure to consider a relevant supervisory notice may be an indication of a breach of corporate due diligence and organizational duties (§ 93 para. 1 AktG; § 43 para. 1 GmbHG; § 25a para. 1 German Banking Act (KWG)). Whether a breach of duty has actually occurred must be assessed based on the specific impact on the institution, the risk analysis carried out, the documented decision-making criteria, and the appropriateness of the measures taken (§ 93 para. 1 sentence 2 AktG; § 5 paras. 1?4 German Money Laundering Act (GwG)).

Recourse risk: If the institution incurs damages as a result of culpable breaches of organizational or supervisory duties, claims for compensation against responsible members of the governing bodies may be considered under the conditions of the applicable company law (Section 93 Paragraph 2 of the German Stock Corporation Act; Section 43 Paragraph 2 of the German Limited Liability Companies Act). Whether and to what extent official fines or related expenses are also recourseable requires a separate legal examination in each individual case.

3.) Criminal Law Risks

Money laundering by omission (§ 261 of the German Criminal Code): Criminal risks can arise in exceptional individual cases when specific illicit assets are involved and a responsible person intentionally fails to take necessary measures despite an existing legal obligation to act (§ 261 para. 1, 2 of the German Criminal Code in conjunction with § 13 para. 1 of the German Criminal Code). Deficiencies in the prevention or control system do not, in themselves, constitute grounds for criminal liability for money laundering by omission.

Negligent money laundering (§ 261 para. 6 of the German Criminal Code): Intent is not required for criminal liability. Negligent money laundering (§ 261 para. 6 of the German Criminal Code): Criminal liability requires that the origin of a specific asset from an unlawful act is not recognized through gross negligence (§ 261 para. 6 of the German Criminal Code). Disregarding relevant risk indicators may be significant in the overall assessment, but does not automatically fulfill the elements of the offense.

4.) Supervisory measures

Special audits and orders (§ 44 para. 1 KWG, § 46 KWG): Within the scope of its statutory powers, BaFin can order audits, request information and documents, and take appropriate supervisory measures in the event of identified deficiencies (§ 44 para. 1 KWG; §§ 45, 46 KWG; § 51 para. 2 GwG). The type and intensity of the measures depend on the severity, duration, and significance of the identified deficiencies. If deficiencies are identified in the vIBAN business, measures up to and including the restriction of business operations may be imposed.

Reliability of Managing Directors ("Fit & Proper"): Persistent or serious deficiencies in the implementation of regulatory requirements may lead BaFin to question the professional suitability and reliability of the managing directors concerned. In extreme cases, this can lead to formal dismissal and a prohibition from exercising management duties pursuant to Section 36 of the German Banking Act (KWG) .

V. Catalogue of Measures

To ensure the appropriate and transparent implementation of BaFin Supervisory Notice 06/2026, the following organizational, procedural, and technical measures should be reviewed on an institution-specific basis and implemented where required by the institution's business model (§§ 5, 6, 10, 15 GwG; § 25a para. 1 KWG). Implementation should be carried out in a documented remediation plan with clear responsibilities, priorities, deadlines, and appropriate involvement of senior management (§ 5 para. 4 GwG; § 6 para. 1 GwG). Implementation should be conducted as a structured project (?remediation plan?) requiring approval from the executive board.

1.) Adaptation of governance and risk analysis

Event-driven update of the risk analysis: In accordance with Section 5, paragraphs 1 and 2 of the German Money Laundering Act (GwG), the institution-specific risk analysis must be reviewed on an event-driven basis to determine whether the risks associated with vIBAN structures are already adequately captured. If an issue exists, the relevant risks should be assessed and documented either in a separate section or transparently within the existing risk categories (Section 5, paragraphs 1?4 GwG; Annex 1 and Annex 2 to the GwG). The risks posed by underground banking and a lack of transparency regarding foreign master accounts must be explicitly assessed.

Board decision & resource allocation: The management must formally approve the updated risk analysis ( § 5 para. 4 GwG ) and, in accordance with § 6 para. 1 GwG in conjunction with § 25a para. 1 KWG, provide sufficient personnel and IT resources for the subsequent adjustments.

2.) Reorientation of KYC and onboarding processes

Transparency regarding end customers (?look-through approach?): The work instructions for customer onboarding and ongoing monitoring must be designed in such a way that the institution receives sufficient information about the end customers, authorized signatories, and beneficial owners behind the vIBANs (Section 10 Paragraph 1 Nos. 1?5 of the German Money Laundering Act (GwG); Sections 11?13 GwG). The scope and depth of information gathering and verification depend on the specific structure and the identified risk (Section 10 Paragraph 2 GwG; Section 15 GwG).

Contractual assurances: The general terms and conditions (GTC) or individual contracts with affiliated payment service providers must be amended to obligate them to transmit end-customer and merchant data to the institution unsolicited and in full. The contracts should grant the institution comprehensive, enforceable, and verifiable rights to information, inspection, and control (Section 6, paragraphs 1 and 2 of the German Money Laundering Act (GwG); Section 25a, paragraph 1 of the German Banking Act (KWG)). If the payment service provider cannot provide the necessary information for legal or factual reasons, it must be examined whether the business relationship can be established or continued in compliance with anti-money laundering regulations (Section 10, paragraph 9 of the GwG).

Application of enhanced due diligence: Multi-stage and cross-border vIBAN models must be included in customer and product classification as risk-increasing factors (Section 5, paragraphs 1 and 2 of the German Money Laundering Act (GwG); Annex 2 to the GwG). A classification as elevated or high risk is based on a documented overall assessment of the relevant risk factors (Section 8, paragraph 1 of the GwG). If an elevated risk is identified, the required enhanced due diligence measures must be applied (Section 15, paragraphs 1?4 of the GwG).

3.) Recalibration of IT and monitoring systems

Adaptation of transaction monitoring: The IT-based monitoring system must be reviewed to ensure that existing scenarios adequately cover the specific risks of vIBAN structures (Section 6 Paragraph 2 No. 2 of the German Money Laundering Act (GwG); Section 10 Paragraph 1 No. 5 GwG). Where gaps exist, additional or adapted detection scenarios, thresholds, and data links must be implemented, validated by experts, and regularly reviewed for effectiveness (Section 25a Paragraph 1 of the German Banking Act (KWG)). In particular, parameters for the following must be implemented:

unusually fast account transactions (velocity checks),

Economically implausible transaction volumes in relation to the customer profile,

generic or missing uses at high volume.

Interface adaptation for Section 24c of the German Banking Act (KWG): The IT infrastructure must be designed to ensure that the customer, allocation, and authorized data required for vIBAN structures are recorded completely, consistently, and in an audit-proof manner (Section 8, paragraphs 1?4 of the German Money Laundering Act (GwG); Section 25a, paragraph 1 of the KWG). The account retrieval procedure pursuant to Section 24c of the KWG must include the information covered by the legally required data scope (Section 24c, paragraph 1 of the KWG). Further KYC, allocation, and transaction data must be stored in the designated internal systems (Section 8 of the GwG; Section 10, paragraph 1, no. 5 of the GwG). Any technical gaps must be closed immediately.

4.) Ongoing monitoring and personnel

Regular monitoring of PSPs: The integrated payment service providers are subject to close, ongoing monitoring (Section 10 Paragraph 1 No. 5 of the German Money Laundering Act (GwG)). If an integrated payment service provider fails to provide required end-customer, authorized, or transaction information, provides it late, or provides it in insufficient quality, appropriate escalation measures must be initiated (Section 10 Paragraph 1 No. 5, Paragraph 9 GwG; Section 15 GwG). Depending on the severity and duration of the deficiency, additional control measures, restrictions on individual services, suspension of the use of vIBAN, or ? subject to legal and contractual requirements ? termination of the business relationship may be considered (Section 10 Paragraph 9 GwG).

Targeted staff training: Employees in the areas of payments, KYC, AML analysis and customer service must be trained promptly and demonstrably on the risk indicators formulated by BaFin and the internal process changes ( § 6 para. 2 no. 6 GwG ).

VI. Conclusion

BaFin Supervisory Notice 06/2026 establishes a specific need for review and, where applicable, adjustments for institutions with direct or indirect exposure to vIBAN (§§ 5, 6, 10, 15 GwG; § 25a para. 1 KWG). Affected institutions should promptly determine and document whether their risk analysis, KYC and onboarding processes, contractual information rights, monitoring systems, and data management adequately cover the specific risks of multi-tiered and cross-border vIBAN structures (§ 5 paras. 1?4 GwG; § 8 GwG; § 10 para. 1 nos. 1?5 GwG).

Sole knowledge of the master account holder may be insufficient if the institution cannot adequately assess the end customers, beneficial owners, and payment flows behind the viBANs (§ 10 para. 1 nos. 1?5, para. 2 GwG; §§ 11?13 GwG). Therefore, a risk-oriented level of transparency is required, enabling effective customer due diligence, ongoing monitoring, handling of suspicious transactions, and fulfillment of statutory documentation and disclosure obligations (§ 8 GwG; § 10 para. 1 no. 5 GwG; § 43 para. 1 GwG; § 24c para. 1 KWG).

If, despite a clear risk, appropriate review or implementation is omitted, supervisory measures may be taken, and, under the respective legal conditions, risks may arise under administrative, civil, or criminal law (§§ 44?46 KWG; § 56 GwG; §§ 30, 130 OWiG; § 93 para. 2 AktG; § 43 para. 2 GmbHG; § 261 StGB). However, liability or organizational negligence does not automatically follow from individual implementation deficiencies, but always requires an examination of the specific duties, responsibilities, and circumstances of the individual case.

S+P Editorial Team

VII. List of Sources

European law (Official Journal of the European Union)

Regulations: Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (EU Anti-Money Laundering Regulation ? AMLR) (OJ L 2024/1624): https://eur-lex.europa.eu/...:32024R1624 , accessed on 05.08.2026.

National law Germany (Federal Law Gazette / Laws on the Internet)

Money Laundering Act (GwG): Act on Tracing Proceeds of Serious Crimes (Money Laundering Act) of 23 June 2017 (Federal Law Gazette I p. 1822): https://www.gesetze-im-internet.de/... , accessed on 5 August 2026.

Banking Act (KWG): Act on Banking in the version published on 09.09.1998 (Federal Law Gazette I p. 2776): https://www.gesetze-im-internet.de/... , accessed on 05.08.2026.

Administrative Offenses Act (OWiG): Act on Administrative Offenses as promulgated on 19 February 1987 (Federal Law Gazette I p. 602): https://www.gesetze-im-internet.de/... , accessed on 5 August 2026.

Official publications and announcements

Federal Financial Supervisory Authority (BaFin): Supervisory Notice 06/2026 (A) on the risks of virtual IBANs in connection with underground banking dated 27 July 2026: https://www.bafin.de/... , accessed on 5 August 2026.

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