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 whose series the previous year’s report traced back to 2020 is missing. Suspicious activity reports with a crypto connection stood at 9,302 in 2022, 8,049 in 2023 and 8,711 in 2024. In the 2025 report the number does not appear at all.

The analysis reads that absence in light of two instruments that address the blind spot from different directions. Since 1 March 2026 the new reporting ordinance under the German Anti-Money Laundering Act (GwG-Meldeverordnung) makes the blockchain transaction ID a mandatory field whenever a report involves crypto-assets and the reporting entity has the ID. The FIU's guidance paper on alternative payment methods and new technologies, published in July 2026, describes the typologies that caseworkers and compliance teams should recognise and asks them to set a dedicated crypto indicator. The first works by technical enforcement; the second depends on whether someone recognises the pattern.

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