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Public access to German Ultimate Beneficial Owner registry

The judgment of the European Court of Justice (ECJ) of the 22nd of November 2022 in joint cases C-37/20 and C-601/20 provides that the rule of the EU Money Laundering Directive is invalid. The latter provides EU-wide that the information on the beneficial owners of the companies or other legal entities entered in the transparency register are accessible to all members of the public in all cases.

Because of this decision, the German Transparency Registry made an announcement on the 12th of December 2022 that members of the public now have to justify the request for inspection when submitting the application and demonstrate a legitimate interest in the inspection. The definition of legitimate interest includes (but is not limited to) the request when the information in your own entry is to be checked (so-called self-disclosure), or with journalists and non-governmental organizations (NGOs) in research related to money laundering or terrorist financing, or if another close connection to money laundering related offences are demonstrated.