Lately, quite a few companies have received so-called discrepancy reports from the German Federal Gazette (“Bundesanzeiger”), the authority in charge of keeping the German transparency register. The number of these reports being submitted has increased significantly recently. Once you receive a discrepancy report, there are quite a few things to observe.

On 5 May 2023, the Federal Office of Administration (FOA), the competent authority for the German Transparency Register, has once again published new interpretation notes to the German Anti-Money Laundering Law.
In these, the FOA now also comments for the first time on the extended transparency register obligations of foreign companies and legal entities such as foundations and trusts (“foreign associations”) with direct or indirect real estate ownership in Germany introduced by the Sanctions Enforcement Act II.