The Federal Ministry of Justice recently presented a new draft criminal law designed to better combat money laundering. While the draft met with approval on some fronts, numerous points of criticism were raised by money laundering investigators and private enterprise. In his response to the draft, Senior Researcher Benjamin Vogel criticizes the fact that the proposed reworking of the definition of money laundering lacks a convincing criminal policy concept. In essence, a regulatory model is being suggested for adoption that has already lead to less than convincing results in other countries. Moreover, the draft law also raises several constitutional concerns.