The Background: As part of the implementation
of the European Anti-Money Laundering Directive (EU Directive
2015/849), a new German Money Laundering Act has come into
effect.
The Action: While the "old" Money
Laundering Act addressed certain parties that are typically
targeted by money laundering actions and thus have to take
preventative measures (such as banks), the new Money Laundering Act
also imposes obligations on all German companies—to collect,
store, and file information on their beneficial owners with a new
central register, the Beneficial Ownership Register
("BOR").
Looking Ahead: The new Money Laundering Act
came into effect on June 26, 2017, and the BOR will be available
for inspection as of December 27, 2017.
On June 26, 2017, a new Money Laundering Act came into force in
Germany. It provides for the Beneficial Ownership Register
(Transparenzregister, "BOR"),
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It goes without saying that in the course of a public or private contract, the parties involved may have to manage and process a large amount of personal data of the interested third parties.
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