When Fraud Becomes Money Laundering: The German FIU Annual Report 2025

The 2025 annual report of Germany's Financial Intelligence Unit sets a new thematic focus: fraud. At the same time, a figure that the FIU had published for three consecutive years is missing. Suspicious activity reports with a crypto connection stood at 9,302, then 8,049, then 8,711. In the 2025 report the number does not appear at all.

The analysis reads that absence as more than an editorial choice. The established counting method measured a label rather than the phenomenon, and it undercounted precisely the fraud-driven flows that now dominate the caseload. Two instruments address the resulting blind spots from different directions. The new reporting ordinance under the German Anti-Money Laundering Act (GwG-Meldeverordnung) standardises what obliged entities must report and how. The FIU's guidance paper on alternative payment methods and new technologies, published in July 2026, sharpens what caseworkers and compliance teams should recognise in the first place.

One gap closes by regulation. The other closes only at the speed at which people learn. The article argues that this second, human gap is the one that decides whether fraud proceeds are detected while they can still be traced.