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On 26 June 2017 the new German anti-money laundering act has entered into force. This law is based on the Fourth Money Laundering Directive of the EU (No 2015/849; the 4MLD). Besides inter alia meeting increased risk demands and the intensified financial penalties, the 4MLD prescribes a transparency register in the foreseeable future.

The register is based on Art. 30 of the 4MLD and shall allow more transparency inside of the companies with the intention to complicate the abuse of the financial system by terrorists, money launderers and other persons having controlling power. The European Union wants to create a European network of registers via the Central European Platform.

Its basic goal is to centrally store information about the beneficial owners of all entities and partnerships as well as of foundations and trusts and to make such information accessible to governmental authorities, the people who need to perform customer due diligence and any other person who shows a legitimate interest in having such information.

What is the content of the transparency register?

The transparency register gives information about every beneficial owner, who has a direct or indirect financial stake or controls the company. The register will be in electronic form and the information will be presented in a chronological order.


Dr. Holger Lutz is co-head of the German Information Technology Group and is based in Baker McKenzie's Frankfurt office. He studied law at the Johann Wolfgang Goethe-University in Frankfurt/Main. He also studied at the University of Edinburgh and gained an "LL.M. in Innovation, Technology and the Law". During his legal clerkship he worked for a German data protection authority as well as international law firms. In 2008 he obtained his Doctor of Law degree on a topic related to software licenses in Frankfurt/Main.



Dr. Franz Clemens Leisch is a partner in Baker McKenzie Partnerschaft von Rechtsanwälten, Wirtschaftsprüfern und Steuerberatern mbB, based in Munich, Germany. Dr. Leisch's practice focus in companies in all areas of corporate and capital markets law. He focuses on corporate action, corporate compliance and corporate litigation.