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Money laundering in Germany when you live abroad

A German public prosecutor is investigating you for money laundering, and you do not live in Germany. This page follows the wording of § 261 StGB and says what German criminal procedure can reach from there and what it cannot.

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The accusation under § 261 StGB

§ 261 Abs. 1 Satz 1 StGB covers dealing with an object that derives from an unlawful act (rechtswidrige Tat). It sets out four forms of conduct with one range of penalty: imprisonment of up to five years or a fine. Under Absatz 3 the attempt is punishable too. Absatz 4 sets three months up to five years, without the alternative of a fine, for a person who commits an act under Absatz 1 or Absatz 2 as an obligated entity under § 2 GwG.

Where you live changes none of that. German criminal law applies to offenses committed within Germany (§ 3 StGB), and § 9 Abs. 1 StGB names several places at which an offense counts as committed, among them the place where the perpetrator acted and the place where the result belonging to the definition of the offense occurred. Which of those places lies in Germany depends on what the file says you did. A payment that ran through a German account does not settle that question by itself; the file has to show an act or a result here.

What reaches you first is usually a letter inviting you to comment (Anhörungsschreiben). An explanation of where the money came from, given without knowledge of the file, stays in the file.

Arrested, searched or held in custody in Germany: your rights from the first hour
On this page: a predicate offense committed abroad under § 261 Abs. 9 StGB, what the file has to establish about conduct and knowledge, the securing of accounts inside and outside Germany, detention and a residence abroad, your presence at a hearing, and how I work from a distance.

A predicate offense committed outside Germany (§ 261 Abs. 9 StGB)

Absatz 9 puts objects that derive from an act committed abroad on the same footing as an object within the meaning of Absatz 1. It attaches two conditions that apply together. The act has to be one that would be an unlawful act under German criminal law. On top of that, either Nummer 1 or Nummer 2 has to be met.

Nummer 1 turns on the law of the place where the act was committed: it has to be punishable there. Nummer 2 does not turn on that at all. It points to a list of provisions and conventions of the European Union and is met where the act is one that is to be made punishable under one of them. That list names, among others, corruption, drug trafficking, organized crime, human trafficking, the sexual abuse of children and terrorism.

For the defense that means the file has to say which act abroad is assumed and which of the two routes carries it. Where it relies on Nummer 1, the law of that other state becomes part of the case. I do not advise on the law of your country of residence; it has to be established in the German proceedings.

What the file has to establish

Which of the four numbers of Absatz 1 Satz 1 is charged decides what has to be proved. Nummer 1 covers concealing the object. Nummer 2 covers exchanging, transferring or removing it, but only where the person acts with the intent to frustrate its discovery, its confiscation or the investigation of its origin; without that intent the number drops out. Nummer 3 covers procuring the object for oneself or for a third party. Nummer 4 covers keeping it or using it for oneself or for a third party, and only where the person knew its origin at the time at which he obtained it.

Satz 2 takes the cases of Nummer 3 and Nummer 4 out again in respect of an object that a third party obtained beforehand without thereby committing an unlawful act.

Absatz 6 is not a milder reading of Absatz 1 It carries a range of its own, imprisonment of up to two years or a fine, for the person who in the cases of Absatz 1 or 2 leichtfertig fails to recognize that the object is one within Absatz 1.

I leave that word in German. "Reckless" is not a translation of it: recklessness carries the awareness of the risk, while Absatz 6 applies by its wording to someone who did not recognize the origin.

In particularly serious cases Absatz 5 provides six months to ten years, with two regular examples: acting on a commercial basis, and acting as a member of a gang formed for the continued commission of money laundering.

Accounts and assets

A German court does not freeze a foreign account itself. Inside Germany the securing runs through the Vermögensarrest. Under § 111e Abs. 1 Satz 1 StPO it may be ordered, to secure enforcement, against the movable and immovable property of the person concerned where the assumption is justified that the conditions for the confiscation of the value of proceeds are met. Satz 2 changes the verb: where there are urgent grounds for that assumption, the arrest is as a rule to be ordered.

Within the European Union the enforcement runs through Regulation (EU) 2018/1805. Article 1(1) lays down the rules under which the Member States recognize and enforce, in their territory, freezing orders and confiscation orders issued by another Member State in the framework of proceedings in criminal matters. Where the order freezes a sum of money, Article 4(4) has the issuing authority transmit the freezing certificate to the Member State in which it has good reasons to believe that the person the order is directed against holds property or income; where the order freezes specific items of property, Article 4(5) points instead to the Member State in which those items are believed to be.

The Regulation does not reach every Member State; its own recitals record that not all of them took part in its adoption, and those that did not are neither bound by it nor obliged to apply it. Beyond its reach there is the route of mutual legal assistance. I act in the German proceedings against the order, not before authorities abroad.

Your presence at the hearing

§ 230 Abs. 1 StPO is short: no main hearing takes place against a defendant who has failed to appear. Absatz 2 belongs with it. Where the absence is not sufficiently excused, the court is to order that the defendant be brought before it or is to issue an arrest warrant, to the extent that this is required in order to conduct the main hearing.

The rule has two exceptions Two provisions qualify Absatz 1. § 232 Abs. 1 Satz 1 StPO lets the hearing be held without the defendant where he was properly summoned, was told in the summons that it may be held in his absence, and where no more than a fine of up to 180 daily rates, a warning with sentence reserved, a driving ban, confiscation, destruction or rendering unusable is to be expected. § 233 Abs. 1 Satz 1 StPO lets him apply to be released from the duty to appear where no more than six months of imprisonment or a fine of up to 180 daily rates, alongside those same measures, is to be expected. Absatz 2 belongs with it: a defendant released from the duty to appear has to be examined about the charge by a commissioned or requested judge, and that examination may run by video link to the place where he is.

§ 234 StPO entitles the defendant, to the extent that the main hearing can take place without him being present, to be represented by a defense lawyer holding a proven authority to represent him. The condition sits in the first half of that sentence.

The route that most often brings a case to a close without a journey runs through the penalty order (Strafbefehl). It is open only in proceedings before the Strafrichter and in proceedings falling to the Schöffengericht, only for a Vergehen, and only on a written application by the public prosecutor's office (§ 407 Abs. 1 Satz 1 StPO). Satz 2 tells that office to make the application where, on the outcome of the investigation, it does not consider a main hearing necessary. Whether it takes that view is its own assessment; the accused has no right to apply for a penalty order.

Once a penalty order has been served, § 410 Abs. 1 StPO gives two weeks to lodge an objection; without a timely objection it is equivalent to a final judgment (Absatz 3). Where an objection is lodged, § 411 Abs. 2 Satz 1 StPO lets the defendant be represented in the main hearing by a defense lawyer holding a proven authority to represent him. It presupposes the penalty order and is not open in every set of proceedings.

Detention and a residence abroad

§ 112 Abs. 1 Satz 1 StPO allows pre-trial detention only where the suspect is strongly suspected of the offense and a ground for detention exists. Satz 2 forbids it where it is out of proportion to the significance of the case and to the sentence or measure to be expected.

The ground for detention in Absatz 2 Nr. 2 is the risk of flight: that, on an appraisal of the circumstances of the individual case, there is a risk that the suspect will evade the criminal proceedings. The opening words of Absatz 2 require specific facts. A residence abroad is one fact among several, and the wording does not turn it into a ground for detention. How a particular court weighs it is not something I predict.

If a request to hand you over reaches you

Extradition runs as a separate procedure, with rules and deadlines of its own. The English material on it is on my dedicated site auslieferung.info/en.

How I work on a case from a distance

The first step is access to the file (Akteneinsicht). Nothing is said on your behalf before I have read it. The file has to show which act is assumed as the predicate offense, which conduct under Absatz 1 is attributed to you, and what the conclusion about knowledge or Leichtfertigkeit rests on.

File access and written submissions run electronically, I correspond with you in English, and I travel to the court for a questioning or a hearing.

Several questions around such an investigation are not criminal defense, and I do not take them on: the tax treatment of the amounts, the law of your country of residence, your residence status, your position toward an employer, and civil claims between you and your bank. The fee side is explained on the fees page; I work on the basis of a fee agreement.

Common questions

I live abroad and I am under investigation in Germany. What happens now?
German criminal law applies to offenses committed within Germany (§ 3 StGB), and § 9 Abs. 1 StGB names several places at which an offense counts as committed, among them the place where the perpetrator acted and the place where the result belonging to the definition of the offense occurred. Which of those places lies in Germany depends on what the file says you did. A payment that ran through a German account does not settle that question by itself; the file has to show an act or a result here. What arrives first is normally an invitation to comment, not a charge. My first step is access to the file, and until that has happened I advise against giving any account of where the money came from.
Can my accounts outside Germany be frozen?
Not by a German order acting on a foreign bank directly. Inside Germany the securing runs through the Vermögensarrest under § 111e Abs. 1 Satz 1 StPO. Within the European Union, Regulation (EU) 2018/1805 lays down the rules under which the Member States recognize and enforce, in their territory, freezing orders and confiscation orders issued by another Member State in the framework of proceedings in criminal matters (Article 1(1)), and, where the order freezes a sum of money, Article 4(4) has the issuing authority transmit the freezing certificate to the Member State in which it has good reasons to believe that the person the order is directed against holds property or income; where the order freezes specific items of property, Article 4(5) points instead to the Member State in which those items are believed to be. The Regulation does not bind every Member State, and beyond its reach the route is mutual legal assistance.
Do I have to travel to Germany for the proceedings?
No main hearing takes place against a defendant who has failed to appear (§ 230 Abs. 1 StPO). Absatz 2 belongs with it: where the absence is not sufficiently excused, the court is to order that the defendant be brought before it or is to issue an arrest warrant, to the extent that this is required in order to conduct the main hearing. Two provisions qualify Absatz 1. § 232 Abs. 1 Satz 1 StPO lets the hearing be held without the defendant where he was properly summoned, was told in the summons that it may be held in his absence, and where no more than a fine of up to 180 daily rates, a warning with sentence reserved, a driving ban, confiscation, destruction or rendering unusable is to be expected. § 233 Abs. 1 Satz 1 StPO lets him apply to be released from the duty to appear where no more than six months of imprisonment or a fine of up to 180 daily rates, alongside those same measures, is to be expected. Absatz 2 belongs with it: a defendant released from the duty to appear has to be examined about the charge by a commissioned or requested judge, and that examination may run by video link to the place where he is. Where a case is dealt with by a penalty order and an objection is lodged, § 411 Abs. 2 Satz 1 StPO lets the defendant be represented in the main hearing by a defense lawyer holding a proven authority to represent him. That route presupposes the penalty order and is not open in every set of proceedings.
The alleged predicate offense happened outside Germany. Does § 261 StGB still apply?
It can, through § 261 Abs. 9 StGB. Objects that derive from an act committed abroad are equivalent to an object within the meaning of Absatz 1 where the act would be an unlawful act under German criminal law and, in addition, either is punishable at the place where it was committed (Nummer 1) or is to be made punishable under one of the provisions and conventions of the European Union listed there (Nummer 2). Both halves have to be met, and Nummer 2 does not depend on the law of the place where the act was committed.
Can Germany request my extradition?
That turns on where you are and on what is being alleged, and it is not decided in the investigation file you have been written to about. Extradition runs as a separate procedure, with rules of its own and deadlines of its own. The English material on it is on my dedicated site auslieferung.info/en.
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