Not all lawyers are "obliged entities" within the meaning of the AMLA.
According to Section 2 para. 1 no. 10 GwG, lawyers, chambered legal advisors,
patent attorneys and notaries are obligated if they
a) participate in the planning and execution of the following transactions
for their clients:
aa) buying and selling real estate and commercial enterprises,
bb) managing money, securities or other assets,
cc) opening or managing bank, savings or securities accounts,
dd) raising the funds required to establish, operate or manage
companies,
ee) establishing, operating or managing trusts,
companies or similar structures or
b) carrying out financial or real estate transactions in the name and for the account of the client.
2In-house lawyers
This also applies in principle, as follows from Section 6 (3) GwG, to
in-house lawyers if they carry out the aforementioned catalog transactions as part
of their professional activity as employees of a company.