Following a special audit ordered by BaFin, various serious deficiencies in the business processes of the payment platform Unzer E-Com GmbH were identified. In addition to trading with dummy companies and connections to customers who are involved in gang-related fraud, the BaFin's far-reaching measures were prompted in particular by the inadequate implementation of obligations under money laundering law and the incomplete transaction monitoring.
Unzer is a payment institution and is accordingly subject to BaFin supervision. The company mainly acts as a payment platform for over 70,000 merchants and generated 176 million euros in revenue last year. BaFin's special audit was to examine whether sufficient precautions against money laundering had been established.
BaFin's measures include the ban on new customers with immediate effect, which restricts the company's business to existing customers. In addition to the payment of a fine of 350,000 euros, the appointment of a special BaFin representative will in future serve to monitor the rectification of the deficiencies and document its progress. Initial changes within the corporate structure and development have already been implemented through a new advisory board, which will serve as an advisor in the compliance area, among other things.
From the point of view of CURENTIS AG, it is not only necessary to sharpen transaction monitoring using concrete indicators and controls, but also to optimize the know-your-customer processes. Only by carrying out periodic, event-independent KYC measures during the course of a business relationship will Unzer be able to check its registered merchants, fulfill its due diligence obligations and minimize its own risk of involvement in money laundering.