Germany's BaFin orders NordLB to remediate AML customer-data backlog

Germany's financial supervisor BaFin has ordered Norddeutsche Landesbank Girozentrale (NordLB) to remediate significant deficiencies in customer due diligence and a considerable backlog in updating customer data, according to a public notice published on 3 August 2026. The measure carries no monetary fine but obliges the Hanover-based Landesbank to submit and implement a customer-data-updating concept to bring its anti-money-laundering controls back into compliance with the law.

The order has been legally binding since 14 June 2026 and was made public on Monday under BaFin's disclosure regime for supervisory measures. The regulator found that NordLB had violated the German Money Laundering Act, known as the GwG, through deficiencies in its processes and a considerable backlog in updating customer data.

SCOPE OF THE ORDER

According to the notice, the supervisor identified significant deficiencies in the bank's customer due-diligence processes together with a considerable backlog in the periodic updating of customer information. Under the GwG, banks must among other things continuously monitor business relationships and ensure that the relevant documents, data and information are kept up to date, BaFin said.

BaFin also ordered that all customer data that had not been updated be brought to a current and complete state in line with the legal requirements.

NordLB said it was working intensively to meet the requirements, that the required concept had been developed and was being consistently implemented, and that it was in close, constructive and solution-oriented exchange with the supervisor. The bank said the order related to the need to further develop and harmonise existing processes rather than to a general failure of its prevention system.

REMEDIATION RATHER THAN FINE

Rather than imposing a monetary penalty, BaFin has required NordLB to draw up and put into effect a formal concept for updating customer data.

In mid-July it emerged that BaFin had also found shortcomings in the anti-money-laundering controls of Landesbank Hessen-Thüringen (Helaba), particularly in customer identification and the review and updating of customer data. The notice was published on BaFin's website.