BaFin fines abcfinance GmbH €90,000 for filing suspicious transaction reports late

Why it matters to AML professionals

Supervisors treat the timing of a suspicious transaction report as a requirement in its own right, not only whether a report is filed. A report that is correct but late can still lead to a fine. AML professionals should know their firm's internal timelines from alert to decision to filing, and flag backlogs before they cause late reports.

Red flags in this case

• Alerts or internal referrals waiting weeks for a decision on whether to report
• A growing backlog of cases in the investigations or reporting team
• Reports filed long after the date the suspicion was first raised internally
• No recorded date showing when the suspicion was formed

If this landed in your queue

1. Record the date and time you first formed a suspicion, since the reporting clock is often measured from that point
2. Escalate straight away if a case meets the reporting threshold, rather than waiting for a batch or a weekly review
3. Tell your team lead if your caseload means reportable cases will wait, so work can be reassigned
4. Follow your firm's procedure on deadlines for filing with the FIU and keep proof of the filing date

What control failed

Suspicious activity reporting. BaFin said abcfinance GmbH filed several suspicious transaction reports late in April 2025.

Key terms

Suspicious transaction report (Verdachtsmeldung)

A report a firm must send to the national Financial Intelligence Unit when there are indications that funds or a transaction may be linked to money laundering or terrorist financing.

Without delay (unverzüglich)

The German legal standard for timing: the report must be made promptly, without unjustified hesitation.

Rechtskräftig

Legally final: the decision can no longer be appealed.

Interview angle

What would you do if you found a backlog of cases that should already have been reported to the FIU?

Explain that you would escalate immediately to the MLRO or compliance lead, prioritise the oldest and highest-risk cases, file the reports that meet the threshold, and document the reasons for the delay and the fix so it does not happen again.