The civic movement Finanzwende strongly criticizes Federal Finance Minister Christian Lindner (FDP) over the 'Law to Combat Financial Crime'. The law is deemed completely inadequate in its essential points to effectively combat money laundering and other offenses, stated Konrad Duffy, Finanzwende's expert on financial crime, during a press conference in Berlin. "Christian Lindner announced a major reform and then fumbled the ball."

With the draft of the 'Financial Crime Prevention Act', Lindner is responding to the 2022 review by the international anti-money laundering organization FATF (Financial Action Task Force). According to the FATF report, the enforcement of anti-money laundering laws in Germany is in poor shape. This is due in part to the fragmented oversight in federal Germany, where more than 300 authorities in states and municipalities are responsible. There are also issues with law enforcement, resulting in fewer convictions. The responsibility for this lies with the federal states. Lindner had already promised the establishment of a Federal Financial Crime Office last year to consolidate oversight at the federal level. The new Federal Authority for the Fight against Financial Crime (BBF – Bundesoberbehörde zur Bekämpfung von Finanzkriminalität) was supposed to have jurisdiction in the investigation and clarification of important cross-border cases. The draft from the Federal Ministry of Finance was officially available since September 13.

The Federal Financial Crime Office is still a good idea, Duffy acknowledged, but the implementation has failed. "The new entity does not have supremacy, but is rather at the children's table," Duffy stated, referring to the draft. There is no real consolidation of competencies there, added Finanzwende Fellow Michael Findeisen, who formerly led the money laundering and payment transactions department at the Federal Ministry of Finance. The BBF will be installed alongside existing entities such as the Federal Criminal Police Office (BKA) and isn't even the primary point of contact for international organizations like Interpol. Also, concerning non-financial sector anti-money laundering oversight, there is no fresh start. The new agency is only meant to work in a coordinating role. Thus, the fragmented oversight remains in place. Furthermore, Finanzwende laments that the law only focuses on money laundering with international dimensions and the enforcement of sanctions. While these two points are appropriate and important, other areas of financial crime, such as tax offenses, are completely excluded.

According to Finanzwende, Lindner is forgoing the most potent weapon in combating money laundering. Administrative confiscation of assets is entirely absent, although it was included in a previous version of the draft. "If you seriously want to hurt criminals , you have to target their illegally acquired assets," said Findeisen. This instrument already exists in German law for terrorism financing. The financial supervisory authority BaFin is allowed to instruct banks to freeze suspicious funds. The affected parties can challenge this before the administrative court but must prove the legality of the funds there. Findeisen emphasized that the path through administrative courts is effective and complies with the rule of law.