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.

The second act on the effective enforcement of sanctions (Sanctions Enforcement Act II) came into force on 1 January 2023. This includes not only sanctions-related measures, but also amendments to other laws, in particular the German Money Laundering Act, and has implications for the obligations of companies with regard to the transparency register.

On February 10, 2021, the German government passed a draft law amending the German Money Laundering Act (Transparency Register and Financial Information Act Money Laundering – E-TraFinG Gw), which would result in some significant changes to the German Money Laundering Act. The article discusses the changes under the E-TraFinG Gw, its impact on companies in Germany and a recommended course of action.