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New AML guidelines for gambling in Germany

The highest gambling supervisory authorities of the German states have recently published new guidelines on the interpretation and implementation of the German Anti-Money Laundering (AML) Act. Gambling operators and intermediaries have been waiting for an update of the guidelines since the new AML Act that transposes the 4th AML Directive came into force in June 2017. Although the guidelines are not binding for German courts of law, they give valuable insight into how the German gambling authorities would like the AML Act to be applied by gambling operators and intermediaries that are offering their services in Germany. One particular focus of the guidelines is on recommendations for sports betting operators on how to comply with their regulatory anti-money laundering obligations.