Long contract terms, well-known business partners, and predominantly cashless payments: At first glance, the leasing business may seem straightforward. However, this does not mean that money laundering risks are ruled out. Even a properly executed contract does not answer every question regarding the source of the funds or the individuals actually involved.
Anti-money laundering measures in the leasing industry therefore require more than just an identity check at the time the contract is signed. They require transparent risk assessments, clear lines of responsibility, and processes that function effectively throughout the entire business relationship.
This practical perspective was also the focus of a recent continuing education course in which Dr. Alexander Deicke participated on behalf of K11 Consulting.
Effective Date: October 27, 2026.
Dr. Alexander Deicke, Managing Director of K11 Consulting, participated in the online event “Update on Anti-Money Laundering for Leasing Companies” hosted by AH Akademie für Fortbildung Heidelberg GmbH on October 20, 2026.
Speaker Ralf Inderwies addressed topics including identification, risk analysis, internal safeguards, suspicious cases, and the European Anti-Money Laundering Regulation. These key topics are also described on the Heidelberg Academy’s official seminar page.
Alexander Deicke holds the corresponding certificate of participation from the Heidelberg Academy. It is issued in his name and documents the completion of the continuing education program.
For K11, ongoing professional development involves linking regulatory requirements with practical business organization. In the area of anti-money laundering in particular, both aspects must align: the legal requirements and the process used to meet them.
A finance lease is a financial service. As financial service institutions, finance lease companies are generally subject to the obligations under the Money Laundering Act. The legal basis for this is provided by Section 2 of the Money Laundering Act (GwG) in conjunction with the classification under the German Banking Act (Kreditwesengesetz).
This does not mean that every company that rents out items or refers to an offer as a “lease” automatically falls into the same category. The specific business model and the legal requirements are what matter.
For leasing companies subject to these requirements, the anti-money laundering regulations are by no means an issue that will only come into effect with the next European regulation. They are already in effect today.
The risk analysis is intended to identify the risks facing the respective company. Which customers are served? Which products and distribution channels are offered? Which international connections, payment methods, or ownership structures are relevant?
An institution with regional commercial clients may face different risks than a provider with complex international business relationships. A general description of the industry is therefore not sufficient to clearly explain one’s own risk profile.
Under Section 5 of the Anti-Money Laundering Act (GwG), obligated entities must identify and assess their risks. The risk analysis must generally be documented, reviewed regularly, and updated as necessary.
In practice, this becomes relevant when new customer groups, products, or sales partners are added. The risk analysis should account for such changes. It is not a corporate chronicle that, once completed, simply needs a safe place to be stored.
General due diligence obligations include, in particular, identifying the contracting party, any individuals involved, and the beneficial owner. In the case of companies, ownership and control structures must also be adequately understood.
In addition, the business purpose must be assessed and the business relationship continuously monitored. Customer data and documentation must be updated at appropriate intervals based on a risk-based approach. These requirements are set forth in § 10 of the Anti-Money Laundering Act (GwG).
For leasing companies, this means that changes that occur during the term of the contract must be included in the review process. A new beneficial owner, a change in corporate structure, or unusual payment circumstances must not be overlooked simply because everything appeared reasonable at the start of the contract.
A work instruction is only helpful if employees know when and how to apply it. Anti-money laundering efforts therefore require clear procedures, defined responsibilities, training, and appropriate controls.
Section 6 of the Anti-Money Laundering Act (GwG) requires risk-based internal safeguards. Their effectiveness must be monitored; they must be updated as needed.
In this context, the prevention of money laundering is explicitly a management responsibility: According to Section 4 of the Money Laundering Act (GwG), a designated member of management is responsible for risk management and compliance with money laundering regulations. This member must approve the risk analysis and the internal safeguards.
Operational work may be divided among several functions. This does not render management’s responsibility irrelevant.
A hypothetical example: A lessee wishes to pay off a lease agreement unusually early. The larger payment required for this is to come from a third party who has not been involved thus far. The nature of this third party’s business relationship with the lessee remains unclear for the time being.
There may be a legitimate explanation for this. The transaction is not automatically considered money laundering. However, it may warrant a closer examination of the parties involved, the economic context, and whether the transaction is consistent with the known customer profile.
The key is having a well-functioning process: Who identifies the suspicious activity? Who assesses it? What information is documented? When is the responsible anti-money laundering function involved?
If the legal requirements for filing a suspicious activity report are met, the facts of the matter must be reported immediately to the Financial Intelligence Unit, the Central Office for Financial Transaction Investigations. Criminal proof of money laundering is not required for this. Section 43 of the Money Laundering Act (GwG) applies.
Internal audits must not delay the fulfillment of any reporting obligation that has already arisen.
The European Anti-Money Laundering Regulation, or AMLR for short, has already been adopted and is in effect. It will generally take effect on July 10, 2027. It harmonizes key anti-money laundering requirements directly at the European level. It is based on Regulation (EU) 2024/1624.
Leasing companies affected by these changes should therefore assess where future requirements will necessitate adjustments to existing processes. This applies, for example, to customer screening, risk management, internal organization, and documentation.
Not every existing measure needs to be reinvented for this purpose. It makes sense to conduct a structured comparison between existing processes and future requirements.
In this context, a distinction should be made between binding regulations and their effective dates, on the one hand, and drafts and ongoing elaborations, on the other. An announced change does not yet constitute a binding obligation. Conversely, preparations for 2027 do not suspend the current requirements of the Anti-Money Laundering Act (GwG).
This in-depth exploration of the topic is also reflected in the book *Money Laundering and Fraud Prevention—Made Easy*. Alexander Deicke co-authored it with Mira Müller-Liebhafsky and Sebastian Teufel.
The book goes beyond the leasing business. It covers anti-money laundering regulations, operational obligations, and management systems, as well as practical issues related to fraud prevention and the handling of fraud and recovery cases.
The publisher, Duncker & Humblot, currently expects the print edition to be available starting in December 2026. The publisher’s website confirms the release date and the main topics covered.
For more information, please visit our page on “Money Laundering and Fraud Prevention—Made Easy.”
Here are five questions that can help you take a practical look at the current situation:
The answers should not be based solely on guidelines. They should also be verifiable based on actual procedures and documented cases.
Cashless payments and long-term contracts are no substitute for effective anti-money laundering measures. What matters most are appropriate risk assessments, robust customer due diligence, clear lines of responsibility, and the proper handling of suspicious activity.
Through Alexander Deicke’s documented professional development and work on the new reference book, K11 maintains a focus on the topic from both a technical and practical perspective.
For companies subject to these requirements, the key task remains translating regulatory requirements into effective processes—not just by 2027, but starting today.