Marie Lundberg and Sam Sheen are joined by Ina Rothe who explains the twists and turns of using Germany's Company Register (referred to as the Transparency Register) as part of the KYC process. Did you know that Germany has more than one register or that the information you want might be spread across several different registers? Or how about needing to pay to get access to some KYC information and the various exemptions that allow some legal entities to provide nothing at all? If you work with customers who have businesses using German legal entities, this episode is a great practical tutorial on how to wrangle this no-so-transparent corporate register.
AND as they say, serendipity is a funny thing - following the recording of this episode, a new law, the Transparency Register and Financial Information Act, came into force in Germany on 1 August 2021. The changes it introduces are intended to transform the German Transparency Register to provide direct information on beneficial owners for all legal entities with very few exceptions - without having to refer to other registers as has been the case up until now. Many a legal entity so far exempt from notifying the transparency register of their UBOs will now have to make the effort to report UBO information, even if it may already be listed on other registers. There is a transitional period for legal entities to comply and report and users of the transparency register may - in theory - expect completion of UBO input by the end of 2022.