According to Section 23 (1) Sentence 1 No. 3 of the German Anti-Money Laundering Act (GwG), not only obligated entities but also all members of the public — after registration — have access to the Transparency Register, including journalists and researchers. Until early 2020, access required proof of a “legitimate interest.” However, with the implementation of the provisions of the 5th EU Anti-Money Laundering Directive, transparency registers across the EU were made accessible to the general public, partly to overcome the difficulties in determining what constitutes a “legitimate interest.”
In its ruling today (C-37/20 and C-601/20), the European Court of Justice (ECJ) declared the relevant provision of the 5th Anti-Money Laundering Directive invalid in a case from Luxembourg. Making the information in the Transparency Register publicly available without requiring, for example, proof of a legitimate interest constitutes a serious and unjustified interference with the fundamental rights to respect for private and family life and the protection of personal data under Articles 7 and 8 of the Charter of Fundamental Rights of the European Union.
The ruling impacts the German Transparency Register. It remains to be seen how quickly the judgment will be implemented. Public access to the register without appropriate evidence or conditions (such as proof of a legitimate interest) will likely no longer be possible in the near future.
You can find the press release of the European Court of Justice here: HERE
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