BaFin orders Cadence Growth Capital to submit AML records

BaFin’s order requires Cadence Growth Capital GmbH to submit contracts with placement agents and records supporting its customer due diligence under the German Money Laundering Act (GwG).

The BaFin order, published on 11 September, concerns the company’s business relationship with a placement agent. BaFin said the measure is intended to secure future compliance in Cadence Growth Capital’s relationships with placement agents.

BaFin found that Cadence Growth Capital seriously failed to meet its due diligence obligations under the GwG in that relationship. The finding covers identifying the person acting for the placement agent, verifying that person’s power of representation, determining whether the contracting party acts for a beneficial owner and continuously monitoring the relationship.

The authority also found a failure to apply enhanced due diligence where there was potentially increased risk of money laundering or terrorist financing. BaFin defines placement agents in this context as companies or natural persons paid by Cadence Growth Capital to establish contacts with investors or potential target companies.

The operative requirement is document submission. Cadence Growth Capital must provide BaFin with the relevant placement-agent contracts and other documents needed to demonstrate fulfilment of its customer due diligence requirements. The notice does not specify a submission deadline, a reporting form or a separate remediation timetable.

What the order establishes

The legal basis is section 51(2), sentences 1 and 2, of the GwG. BaFin said those provisions allow it to issue orders designed to secure compliance in individual cases with due diligence requirements concerning contractual partners.

The order is case-specific. It addresses the company’s controls in relation to placement agents and the documents required to evidence those controls. The notice does not establish a general requirement for all placement agents to submit records to BaFin or describe a wider measure applying across asset managers or investment firms.

The source does not describe criminal proceedings, an administrative fine or a final finding concerning any placement agent. Its finding concerns Cadence Growth Capital’s failure to fulfil its own customer due diligence obligations. BaFin’s publication does not identify the placement agent involved.

The GwG requires obliged companies, including registered and authorised asset management companies, to identify representatives and verify their authority, establish whether a contracting party acts for a beneficial owner and monitor business relationships and transactions continuously. Enhanced due diligence applies where the risk of money laundering or terrorist financing is increased.

BaFin published the information under section 57(1) of the GwG. The order became final and binding on 6 August 2026.

The notice identifies no further supervisory event or filing deadline. The official BaFin record is the document to monitor for any subsequent submission or supervisory update.