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Germany: Extended obligation to report to the transparency register as of 1 August 2021

The new Transparency Register and Financial Information Act (Transparenzregister- und Finanzinformationsgesetz – “TraFinG”), which came into force on 1 August 2021, has extended the requirement to disclose beneficial owners of certain entities that were previously exempt from reporting.

The deadline to register beneficial owners with the German authorities for entities that were using the exemption under Section 20(2) of the German Anti-Money Laundering Act (GwG) will vary depending on their respective legal form.

Fines of up to EUR 150,000 may be imposed for failure to comply with the Act, rising to EUR 1 million or twice the economic benefit stemming from the breach in case of serious or repeated offences. Financial services providers, as defined in Section 2 Paragraph 1 No. 1 -3, 6-9 GwG, may be hit with fines reaching EUR 5 million or 10% of their total sales.