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Transparency Registry System in Germany

The transparency registry system in Germany plays a crucial role in ensuring the integrity of financial transactions and combating illicit activities. In this article, we will delve into the various stakeholders that have access to different types of data within this registry.

Access Levels for Different Stakeholders

Public Authorities

• Tax authorities and labor inspectors can access commercial register information for investigations.
• Public authorities also have access to bank account information for investigative purposes.
• Payment records are accessible to public authorities for investigations.

Law Enforcement Agencies (LEAs)

• LEAs do not directly access shareholder registers but can obtain access through search warrants issued by a judge during criminal investigations.
• LEAs can request bank account information from financial supervisory authorities and banks, enforced via questioning of witnesses or search and seizure.
• Payment records are accessible to LEAs unless obtained through a search warrant.

Reporting Entities

• Reporting entities with anti-money laundering (AML) obligations in Germany can access the Transparency Registry through a secure online portal or an Application Programming Interface for automatic access.
• They also have restricted access to information on beneficial owners within the registry.

Transparency Registry and Beneficial Ownership

• The beneficial ownership registry in Germany is called the Transparency Registry.
• Information on beneficial owners can only be accessed by those with a legitimate interest.
• Data on individuals and entities within the registry includes name, date of birth, place of residency, nationality, and contact details, among others.

Historical Documents and Public Access

• Historical documents, such as past annual filings, are not publicly accessible.