Planned Amendments to the Transparency Register under the New Financial Crime Prevention Act

The draft bill to improve the fight against financial crime not only includes amendments to the German Anti-Money Laundering Act (GwG) but also introduces several changes related to the Transparency Register.

These include, in particular, the following points:

In the future, if there are justified doubts regarding the authorization to represent an entity when making entries, a corresponding proof may be required.

- From January 1, 2025 at the latest, associations will be able to apply for the right to make entries and communicate with the register solely through a designated authorized representative. This person must first verify their identity, for example via eID or video identification. The aim is to prevent false entries. Authorization must be proven with suitable documentation.

- From January 1, 2027, the place of birth of beneficial owners will be mandatory information. Earlier entries of this data are possible on a voluntary basis.

- From July 1, 2025 at the latest, companies subject to registration obligations will be able to voluntarily submit ownership and control structure overviews to the Transparency Register. Where available, these overviews will be shared with authorities and other obligated entities under the Anti-Money Laundering Act during register access, alongside the standard extract.

- A lack of cooperation in resolving a discrepancy report will be noted in the register extract.

- The register will also be able to initiate a discrepancy check procedure based on its own findings or based on information provided by third parties with a legitimate interest in clarification.

These regulatory requirements may pose significant challenges for obligated companies. The Regpit team is always available to answer your questions and support you in fulfilling your legal obligations.

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