On June 10, 2025, the Financial Intelligence Unit (FIU), the special unit of the German Customs Criminal Police Office, published its annual report for 2024. In it, it highlights current developments in the area of money laundering and terrorist financing. In addition to notable changes in the volume of reports, the report shows that new technologies, crypto assets and other digital assets continue to gain in importance.
Decreasing number of suspicious activity reports and increasing number of analysis reports
In 2024, as in the previous year, the Financial Intelligence Unit recorded a significant decline in suspicious activity reports. The number of reports submitted fell from 322,590 in 2023 to 265,708 in 2024, with the financial sector continuing to lead the way with 253,847 reports. Nevertheless, there was also a decline here compared to 2023 with 310,956 reports. This development is due in particular to the key issues paper published by the FIU and BaFin in June 2023, which lists circumstances that do not trigger a reporting obligation under Section 43 para. 1 AMLA.
Although there was a slight increase in reports in the non-financial sector from 10,374 in 2023 to 10,464 reports in 2024, the sector only accounted for 3.9% of the total number of reports.
The number of analysis reports submitted by the FIU to investigative and security authorities amounted to 87,731 - an increase of eight percent compared to 2023. This corresponds to the increased number of public prosecutor's office reports on public complaints and the outcome of proceedings, including all decisions to discontinue proceedings, which are an important indicator for assessing the effectiveness of the suspicious activity reporting system.
Barbara Scheben
Partner, Audit, Regulatory Advisory, Head of Forensic, Head of Data Protection
KPMG AG Wirtschaftsprüfungsgesellschaft
The number of obliged entities registered with the FIU has tripled - to 98,810. This disproportionate increase is due to the obligation to register, which has been in force since January 1, 2024. The number of reporting entities, on the other hand, remains comparatively low despite the increase: only 4,059 obliged entities submitted reports on suspected cases - just 129 more than in 2023.
Crypto assets as a real money laundering risk - number of suspicious activity reports on the rise
One focus of the current report is on crypto assets: 8,711 suspicious activity reports in 2024 related to transactions with crypto assets. This is around 3.3% of all reports and shows how important digital payments have become in the context of complex money laundering networks. This shows a concentration on a few dominant tokens: Bitcoin, Ethereum, XRP (Ripple), Tether and Litecoin. Transfers to known crypto trading platforms, suspicious wallet addresses or unusual transaction patterns were cited as triggers for the reports.
The increasing use of crypto assets, decentralized financial platforms and other digital payment methods poses new challenges for combating money laundering. In combination with traditional transaction procedures, money flows are becoming more complex and opaque, which is accompanied by increasing anonymity of the beneficial owners. The use of anonymous wallets fundamentally changes and complicates the ability to track transactions.
With regard to the obligated party groups, credit institutions and financial services institutions reported the highest volume of crypto-related reports. A total of 8,456 suspicious activity reports were submitted, with 2,748 of these relating to crypto exchanges, so-called Crypto Asset Service Providers (CASP). The conspicuous activities reported include transactions associated with the darknet, mixing services or online crypto casinos. The majority of the crypto-related suspicious activity reports came from traditional financial players such as credit institutions, financial service providers and payment service providers. They play a central role in monitoring and detecting risks in the crypto sector.
Far-reaching changes for the work of the FIU as a result of the new EU AML package
The EU's Anti-Money Laundering (AML) package will also result in significant changes for the work of FIUs. A uniform set of rules to combat money laundering and terrorist financing will be created across the EU, with the new supervisory authority AMLA (Anti Money Laundering Authority) in Frankfurt at its heart. In addition to its supervisory activities, it coordinates the exchange of information between national authorities and FIUs and thus acts as a central link at European level. The FIUs will be given extended powers to better analyze money laundering and terrorist financing. This includes extended access to various data sources, such as financial, administrative and law enforcement information as well as data on money transfers and crypto asset transfers. Furthermore, if there is a significant money laundering risk, FIUs can instruct obliged entities to monitor transactions or activities processed via bank, payment or crypto accounts for a certain period of time and report on the results.
In view of the constantly and dynamically evolving typologies of money laundering and terrorist financing as well as the internationalization of financial flows, cross-sector prevention is also becoming increasingly important. The FIU Annual Report 2024 makes it clear that digital assets in particular, such as crypto assets, are increasingly being used as a vehicle for money laundering and that various sectors, from traditional banks to crypto service providers and new obliged entities, are affected. It is therefore essential to address the requirements of the AML package and the resulting implementation needs at an early stage. The experts at KPMG will be happy to assist you.
