Germany’s Anti-Money Laundering Act for Car Dealers (GwG): Obligations, Fines, and Public Naming

The Geldwäschegesetz (German Anti-Money Laundering Act, GwG) was long treated in the used car trade as an issue “for the big players.” Legally, that is incorrect. Every commercial vehicle dealer is an obliged entity under the GwG from the first vehicle onward, regardless of price. Enforcement is also becoming stricter. In 2025, the Verwaltungsgericht Ansbach (Ansbach Administrative Court, VG Ansbach) confirmed that authorities may publish violations online under the responsible party’s real name, a practice known in German as the “Internetpranger,” or online naming-and-shaming list, under section 57 GwG.

This article explains exactly when the obligations apply, particularly the €10,000 cash-payment threshold, what must be documented, why the goAML registration deadline for car dealers has already passed, and what will fundamentally change under the EU Anti-Money Laundering Regulation from July 2027.

Reviewed and updated on July 14, 2026: The future €3,000 identity check has been clearly separated from the general €10,000 cash limit, and the new scope for vehicle dealers has been clarified.

Because evidence under the GwG is fundamentally a documentation issue, it is also worth reviewing how supporting records are organized: → GoBD at a car dealership: what tax authorities actually audit

Quick Definition: Who Is Subject to the GwG in the Automotive Trade?

Every commercial motor vehicle dealer is a “goods trader” within the meaning of the GwG under section 2(1) no. 16 in conjunction with section 1(9) GwG, including in brokerage and agency transactions. By law, motor vehicles are considered high-value goods under section 1(10), sentence 2, no. 5 GwG, with no minimum price. The strict due diligence obligations apply as soon as cash payments of €10,000 or more are made or received within a transaction under section 10(6a) no. 1c GwG, including split payments.

📚 Knowledge base:
Used Car Trade Knowledge Base: Overview and Quick Start

Key Facts

• Every vehicle counts: Section 1(10), sentence 2, no. 5 GwG lists “motor vehicles” without a price threshold. A €3,000 subcompact triggers the same obligations as a sports car.
• €10,000 threshold: Cash payments of €10,000 or more, whether received or made, including vehicle purchases by the dealer, trigger identification and documentation obligations. Related partial payments are added together.
• goAML obligation: Car dealers had to register with the Financial Intelligence Unit (FIU) reporting portal goAML by January 1, 2024, regardless of whether they had ever encountered a suspicious case.
• Public naming: Final measures and non-appealable fines are published on the authority’s website for five years under section 57 GwG, generally under the real name according to the first-instance VG Ansbach ruling.
• Fines: Up to €100,000 per violation; for serious or repeated violations, up to €1 million or twice the economic benefit under section 56 GwG.
• Retention: Five years for ID copies, risk assessments, and transaction records under section 8 GwG, followed by deletion in compliance with data protection law.
• Outlook for 2027: From July 10, 2027, the EU Anti-Money Laundering Regulation (AMLR) prohibits commercial cash payments above €10,000. The limited identity check from €3,000 applies to obliged entities; it does not automatically apply to every dealership.

An Obliged Entity from the First Vehicle: Why the GwG Affects Every Dealer

Obliged-entity status is not based on revenue, legal form, or employee headcount, but on the activity itself. A goods trader is anyone who commercially sells goods, regardless of whose name or account the person acts in under section 1(9) GwG. This also covers pure brokerage and agency transactions. A dealer acting as an intermediary is in no better legal position than a dealer selling its own inventory.

A common misconception is that the GwG applies only to luxury and sports car dealers. The legislature, however, expressly classified motor vehicles as high-value goods by means of a statutory example under section 1(10), sentence 2, no. 5 GwG, without a minimum price. The reason is that vehicles are mobile, retain value, and are easy to trade, making them ideal for placing cash derived from criminal activity. In its national situation report on vehicle crime, the Bundeskriminalamt (German Federal Criminal Police Office, BKA) regularly points to straw-man purchases with cash from drug trafficking, followed by transfers abroad.

The €10,000 Threshold: When Do the Strict Obligations Apply?

Being an obliged entity does not in itself mean that the full set of requirements always applies. Their intensity depends on cash:

• Risk management, consisting of a risk assessment and internal safeguards, is required only if cash payments of €10,000 or more are made or received in transactions under section 4(5) no. 1c GwG.
• General due diligence obligations, including identification and documentation, apply to cash payments of €10,000 or more under section 10(6a) no. 1c GwG, and regardless of any amount threshold whenever there is a specific suspicion of money laundering under section 10(3) GwG.

Partial Payments Are Added Together (Smurfing)

The threshold cannot be circumvented by splitting a payment. If several cash payments have a factual, legal, or temporal connection, typically because they relate to the same purchase agreement, they are added together.

Example: A €4,000 cash deposit when the agreement is signed plus a €6,500 cash payment at handover two weeks later equals €10,500, exceeding the threshold. The identification and documentation requirements must be completed in full, retrospectively if necessary. An important practical distinction is that entirely separate purchases by the same customer months apart are not automatically added together. The connection to the transaction is decisive. If splitting clearly indicates a deliberate attempt to circumvent the rules, that is also a risk indicator that may trigger a suspicious activity report.

The Legal Alternative: No Cash

A business that makes a binding, documented decision not to accept or make cash payments of €10,000 or more, whether split or not, without exceptions, for both sales and purchases, does not have to maintain a risk management system or risk assessment. The suspicious activity reporting obligation under section 43 GwG and the due diligence obligations in cases of specific suspicion remain unaffected.

Required Program: What Exactly Must Be Done?

Anyone who does not rule out cash payments of €10,000 or more must do the following:

→ More detail on KYC: KYC for cash payments at a car dealership explains how identification, detection of split payments, and verification of ultimate beneficial owners (UBOs) work in daily operations.

goAML: The Registration Obligation Many Dealers Overlook

Registration with the FIU reporting portal goAML Web is no longer triggered only by a specific event. The statutory transitional period for motor vehicle dealers expired on January 1, 2024 under section 59(6) GwG. The obligation applies regardless of whether the dealer has ever filed a suspicious activity report.

Anyone who missed the deadline should register without delay at goaml.fiu.bund.de. Supervisory authorities now regularly ask about registration during inspections. A separate fine for failure to register is contemplated in the legislative process for the Finanzkriminalitätsbekämpfungsgesetz (Financial Crime Prevention Act).

FIU figures also show what supervisory authorities are focusing on. Of 265,708 suspicious activity reports filed in 2024, only around 10,500, approximately 4%, came from the entire non-financial sector, even as registrations increased sharply. Auditors are looking precisely at this gap between formal registration and actual reporting behavior.

Anti-Money Laundering Officer: When Is One Mandatory?

For goods traders, supervisory authorities order the appointment of an anti-money laundering officer, plus a deputy, through a general administrative order under section 7(3) GwG. Typical cumulative criteria are:

1. Commercial sale of high-value goods, including motor vehicles,
2. more than 50% of revenue generated from those goods,
3. a minimum number of employees in areas exposed to money-laundering risk, including sales, cash desk, accounts receivable, and management, such as 10 in North Rhine-Westphalia and 15 in Bavaria.

For a typical independent dealer with 1–9 employees, this generally means there is no formal appointment obligation. But take care: exemption from appointing an officer is not an exemption from the obligations. Management itself is then responsible for the risk assessment, KYC, and suspicious activity reports.

Note: Employee thresholds are based on regional general administrative orders and vary by German federal state. The order issued by the dealer’s own supervisory authority, such as a district government, regional authority, or state ministry, is decisive.

Whistleblowing System: Do Not Confuse the HinSchG with Section 6(5) GwG

These are two separate legal regimes that dealerships often confuse:

• Hinweisgeberschutzgesetz (Whistleblower Protection Act, HinSchG): Requires an internal reporting office only for companies with 50 or more employees. A small dealership is not covered.
• Section 6(5) GwG: Requires regardless of employee headcount “appropriate arrangements” that allow employees to report GwG violations while protecting the confidentiality of their identity, provided the business is subject to the risk management obligation.

For a business with three employees, a pragmatic but confidential solution is sufficient, such as a private mailbox accessible only to management or a separate email inbox that only management reviews. The decisive point is that the reporting person must not fear retaliation. A business seeking maximum confidentiality can outsource the function to an external ombudsperson, such as a trusted attorney.

The Public Naming List Under Section 57 GwG: What the VG Ansbach Ruling Means

Section 57 GwG is a mandatory provision. Supervisory authorities must disclose final measures and non-appealable decisions imposing fines on their websites, including the nature of the violation and the responsible individuals or companies, for five years under section 57(4) GwG.

The case: A jeweler had sold luxury watches for cash in 53 cases without filing suspicious activity reports; the funds came from criminal offenses. The authority issued a final confiscation order for €113,640.70 and announced that it would publish her name. The dealer challenged the decision, arguing in part that public naming would jeopardize her manufacturer concessions and therefore her livelihood.

The ruling by VG Ansbach on June 16, 2025, case no. AN 4 K 23.1389: The court dismissed the action. Publication is not a punishment, but an informational measure intended to deter. The criminal-law prohibition on retroactive punishment does not apply, and rights under articles 4, 15, and 16 of the EU Charter of Fundamental Rights do not prevent publication. The key practical point is that the mere risk of significant financial losses or reputational harm does not justify anonymization. Anonymization is designed as a strict exception under section 57(2) GwG.

Application to the automotive trade: Dealer agreements with manufacturers commonly contain compliance clauses. An entry on the public list may strain the contractual relationship and results in exclusion from public tenders. The publication practices of the German federal states are already visible. Among other cases, the Bezirksregierung Arnsberg (Arnsberg District Government) lists a 2024 fine of €12,866 against a car dealer for due diligence violations, under the dealer’s real name. In a furniture-trade case, more than €379,000 imposed on a named manager was published.

Context: This is a first-instance ruling. At the editorial deadline, it had not been conclusively established whether an appeal had been filed with the Bayerischer Verwaltungsgerichtshof (Bavarian Higher Administrative Court, VGH). Administrative practice is nevertheless already following the strict approach.

Fines and Supervisory Practice

Supervision of goods traders rests with the German federal states. In North Rhine-Westphalia, this means district governments; in Bavaria, governments; and in Hesse, regional authorities. Section 56 GwG provides the following penalty framework:

According to the Zentralverband Deutsches Kraftfahrzeuggewerbe (German Federation for Motor Trades and Repairs, ZDK), fines of €50,000 have already been imposed on automotive branches, and fines of €20,000–€40,000 on dealership groups. Disgorgement of profits and, in extreme cases, prohibition from conducting business may also be considered, as may publication under section 57 GwG.

Outlook for July 2027: The EU Anti-Money Laundering Regulation Changes the System

The EU Anti-Money Laundering Regulation (AMLR, Regulation (EU) 2024/1624) applies directly in every member state from July 10, 2027, without national implementing legislation. Three points are central for the automotive trade:

1. €10,000 cash limit under article 80 AMLR: Commercial cash payments above €10,000 will be prohibited, rather than merely subject to documentation requirements. Split payments are expressly covered. Member states may set lower limits. Pure private sales between consumers (C2C) remain exempt.
2. Identity check from €3,000 in cash under article 19(4) AMLR: This limited check applies to occasional cash transactions carried out by obliged entities. It does not automatically make every dealership an obliged entity for every cash payment of €3,000 or more.
3. Redefining the group of obliged entities: In the automotive sector, the new scope includes traders whose regular or principal professional activity is trading in high-value goods. Annex IV covers motor vehicles priced above €250,000. Separately, article 74 requires threshold-based reports for non-commercial vehicle purchases from €250,000, regardless of payment method. How Germany will adapt the GwG or include additional sectors remains open.

Until then, the current GwG obligations continue unchanged, including the risk of public naming.

Common Misconceptions

“This applies only to luxury cars.” Incorrect. Section 1(10), sentence 2, no. 5 GwG lists motor vehicles without a price threshold. A €12,000 subcompact purchased with cash triggers the same obligations as a supercar.

“Below €10,000 in cash, I do not have to do anything.” Incorrect. In cases of specific suspicion of money laundering, such as an obvious straw-man purchase, due diligence and reporting obligations apply regardless of the amount and payment method under sections 10(3) and 43 GwG.

“I do not need an anti-money laundering officer, so the GwG does not affect me.” Incorrect. Exemption from the appointment obligation does not remove the risk-assessment, KYC, and suspicious activity reporting obligations. Management is then responsible.

“I will register with goAML when the first suspicious case arises.” Incorrect. The registration obligation for car dealers was not event-driven. The deadline expired on January 1, 2024. Any late registration should be completed without delay.

Practical note on documentation: Evidence under the GwG depends on being able to prove, for each vehicle, who paid, when, and by which method. Systems that combine purchase, sale, payment method, and customer data in a single vehicle identification number (VIN)-based transaction make this much easier. For example, Autaxo documents the purchase agreement, invoice, payment method, and master customer data with the vehicle. The steps specific to the GwG, including ID documentation, risk assessment, goAML registration, and reporting, must be completed independently.

Internal links:

• Accounting / DATEV: /en/features/accounting-datev/
• Practical GoBD guidance: GoBD at a car dealership: what tax authorities actually audit
• Individual transaction records by VIN: Vehicle trade register in the automotive trade

FAQ About the GwG in the Automotive Trade

Does the German Anti-Money Laundering Act also apply to small, independent car dealers?
Yes. Every person who commercially sells vehicles is an obliged entity, regardless of business size or vehicle price, including in brokerage and agency transactions under section 2(1) no. 16 and section 1(9) GwG.

At what amount must I identify customers who pay in cash?
From €10,000 in cash per transaction, for both sales and purchases under section 10(6a) no. 1c GwG. Where there is a specific suspicion of money laundering, the obligation applies regardless of amount and also to non-cash payments.

Are the deposit and final payment added together?
Yes, if they are connected, typically because they arise under the same purchase agreement. A €4,000 deposit plus a €6,500 cash balance exceeds the threshold. Entirely separate purchases months apart are not automatically added together.

Do I have to register with goAML even if I have never encountered a suspicious case?
Yes. The registration deadline for car dealers expired on January 1, 2024, under section 59(6) GwG. The obligation applies regardless of specific suspicious cases. Any missed registration should be completed immediately.

Can I legally avoid the GwG obligations?
To a large extent, yes, through a documented policy that is followed without exception and prohibits making or receiving cash payments of €10,000 or more, including split payments. This removes the risk management and risk-assessment obligations. The suspicious activity reporting obligation and due diligence obligations in cases of specific suspicion remain.

What is the German “money-laundering naming-and-shaming list”?
It is the obligation of supervisory authorities under section 57 GwG to publish final measures and non-appealable fines on their websites for five years, generally identifying the company and responsible persons. In 2025, VG Ansbach upheld this practice at first instance.

What changes from July 2027?
The EU Anti-Money Laundering Regulation prohibits commercial cash payments above €10,000. The identity check from €3,000 applies to obliged entities and therefore not automatically to every dealership. For high-value vehicles, the AMLR creates a new obliged-entity scope and a separate threshold report for non-commercial purchases from €250,000.

Checklist: Basic GwG Protection at a Car Dealership

• ☐ Cash policy: Will the dealership accept cash payments of €10,000 or more, or prohibit them through a binding policy? Put it in writing and inform the team. The policy also applies to vehicle purchases.
• ☐ goAML registration completed or remedied without delay at goaml.fiu.bund.de.
• ☐ Risk assessment prepared and documented if cash payments of €10,000 or more occur. Use an IHK or authority template and review it annually.
• ☐ Team trained on smurfing, straw-man purchases, and third-party payments, with the training documented.
• ☐ Confidential reporting channel established for employees under section 6(5) GwG. A mailbox or separate inbox is sufficient for a small business.
• ☐ KYC process: Check the original ID, make a copy, and identify the ultimate beneficial owner for corporate customers. Securely retain the records for five years.
• ☐ Payment method documented for every sale; monitor partial payments relating to the same transaction.
• ☐ Suspicious activity reports: Responsibility clarified, goAML access works, and the team knows the prohibition on tipping off under section 47 GwG.
• ☐ German federal state check: Review the general administrative order from the competent supervisory authority concerning the anti-money laundering officer.

Further Articles in the Autaxo Knowledge Base

• KYC / identification for cash payments: KYC for cash payments at a car dealership: obligations, processes, and common mistakes
• GoBD / documentation / locking records: GoBD at a car dealership: what tax authorities actually audit
• Individual transaction records by VIN: Vehicle trade register in the automotive trade: requirements, content, structure, and audit errors
• Special VAT regime: Margin scheme taxation in the automotive trade under section 25a UStG
• VAT pitfalls overall: Common VAT mistakes in the used car trade
• E-invoicing / archiving: E-invoicing from 2025: guide

Legal Bases and Citable German and EU Sources

German legislation and standards:

• Section 1 GwG: Definitions, including goods traders in subsection 9 and high-value goods, including motor vehicles, in subsection 10, sentence 2, no. 5.
• Section 2 GwG: Obliged entities, with goods traders in subsection 1, no. 16.
• Section 4 GwG: Risk management and thresholds for goods traders, with cash payments of €10,000 or more in subsection 5, no. 1c.
• Section 6 GwG: Internal safeguards and a confidential reporting channel for employees in subsection 5.
• Section 7 GwG: Anti-money laundering officer and appointment by supervisory authorities for goods traders in subsection 3.
• Section 8 GwG: Recording and retention obligation for five years.
• Section 10 GwG: General due diligence obligations, thresholds for goods traders in subsection 6a, no. 1c, and suspicion-based obligations in subsection 3.
• Section 43 GwG: Reporting obligation to the FIU.
• Section 47 GwG: Prohibition on disclosing information, or “tipping off.”
• Section 56 GwG: Administrative fine provisions.
• Section 57 GwG: Publication of final measures and non-appealable decisions imposing fines, known as the online naming-and-shaming list, for five years.
• Section 59 GwG: Transitional provisions, including the January 1, 2024 goAML registration deadline for car dealers in subsection 6.

Case law:

• VG Ansbach, judgment of June 16, 2025, AN 4 K 23.1389: Lawfulness of publication under the responsible party’s name pursuant to section 57 GwG, at first instance.

EU law:

• Regulation (EU) 2024/1624 (AMLR): EU Anti-Money Laundering Regulation, including the €10,000 cash limit under article 80, applicable from July 10, 2027.

Authorities and reports:

• FIU Annual Report 2024: Reporting volume and registration trends.
• goAML registration, German Customs/FIU: Registration portal and guidance.
• BKA, National Situation Report on Vehicle Crime 2024: Typologies in the automotive sector.
• Publications under section 57 GwG, Bezirksregierung Arnsberg and Berlin: Examples of publication practice.
• IHK guidance on risk assessments under the GwG: Free template.
• ZDK brochure, “Preventing Money Laundering in the Automotive Trade”: Industry guide.

Note on the legal position: The VG Ansbach ruling is a first-instance decision. Employee thresholds for appointing an anti-money laundering officer are based on regional general administrative orders and must be checked for each German federal state. Information concerning the Finanzkriminalitätsbekämpfungsgesetz reflects the status of the legislative process.

Note: This article provides general information and is not a substitute for legal advice on an individual case.