Conversion and Transfer Policies

The Eurozone has no restrictions on the transfer or conversion of its
currency, and the exchange rate is freely determined in the foreign exchange market.
Germany does not engage in currency manipulation. It was included in the U.S. Treasury’s
Semiannual Report on International Economic and Exchange Rate Policies in October 2013.

Treasury wrote that Germany’s “anemic pace of domestic demand growth and dependence on
exports” has led to a deflationary bias in the Eurozone and the overall global economy.

German policymakers rejected Treasury’s inclusion of Germany in the report, arguing that the country’s
large current account surplus is the result of market forces rather than active government
policies, particularly since Germany, as a Eurozone member, does not control its monetary
policy or its exchange rate. Private sector German economists argue that the current account
surplus is mainly due to a lack of domestic investment in Germany, as German firms prefer to
invest abroad.

Germany is a member of the Financial Action Task Force (FATF) and is committed to further
strengthening its national system for the prevention, detection and suppression of money
laundering and terrorist financing. The last FATF report in 2010 states that Germany has
introduced a number of measures to strengthen its regime for anti-money laundering and the
combating of terrorist financing. Germany has generated a relatively large number of
prosecutions for money laundering and orders to confiscate assets. The anti-money laundering
and counter-terrorist financing framework is not fully in line with the FATF recommendations,
as there are weaknesses in the legal framework and in sanctioning for non-compliance with anti-
money laundering and counter-terrorist financing requirements.

In April 2014, the Finance Minister urged the Justice Minister to initiate concrete measures to prevent that Germany is put
on the OECD’s enhanced follow-up list.