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Discussion and Drinks Updates on the Ultimate Beneficial Owner Register Act – Excusable oversight or criminal liability?

Practical ambiguities in the interpretation of the obligations of the Beneficial Owner Register Act and consequences under fiscal criminal law:

The general reporting obligations and the obligation to confirm the reporting of beneficial owners annually are already firmly anchored in the compliance system in most companies.

In practice, however, there are always ambiguities as to which circumstances exactly trigger a reporting obligation, the specific implementation and the update/confirmation obligations to be observed precisely under the Beneficial Owner Register Act.

Violations can result in significant penalties – up to EUR 200,000 in individual cases. It is therefore worth taking a closer look at these stumbling blocks for managing directors and society.

Main Topics:

  • Identification and verification of beneficial ownership and reporting
  • Update and confirmation obligations
  • Special cases from praxis
  • Penalties
  • Self-Disclosure
  • Practical experience with the Ultimate Beneficial Owner Register Authority and the Fraud Prevention Authority


  • Nikolaus Loudon, Partner, Wolf Theiss
  • Martina Edlinger, Senior Associate, Wolf Theiss