On 26 June 2017, the Act on the Implementation of the Fourth EU Anti Money Laundering (AML) Directive entered into force. It provides for the establishment of a central electronic Transparency Register, according to which all civil law legal entities, registered partnerships, trusts and trust-like legal formations must have their „beneficial owners“ disclosed.
Under the new law, register access (for the time being) is, among others, limited to supervisory authorities and prosecution agencies. In the case of a legitimate interest, however, other persons also have access rights. According to the explanatory memorandum to the new law, in particular, „non-governmental organizations and specialized journalists“ are named. In doing so, „the research needs to serve the preparation of a serious and factual analysis.“
According to the wording of the law, however, there is no limitation to these groups of persons, but access is granted to each person demonstrating to the registering authority that he/she