Discrepancy report (Germany)
Unstimmigkeitsmeldung
Other languages: Deutsch · Français · Español
Duty of obliged entities under the German Anti-Money Laundering Act to report discrepancies between their own findings and the transparency register (section 23a GwG).
For family offices this means: if the entries for their companies differ from their own documentation, they often learn about it from the bank.
In practice
A discrepancy report is due when an obliged entity's own findings on the beneficial owner differ from the transparency register – for example incorrect percentages or missing persons. In practice, it is checked before reporting whether the discrepancy is material and whether it results from an error in the register or in the entity's own records. The report, the reasoning and the register extract are filed so that the process can be followed in an audit.
Distinctions and common mistakes
The discrepancy report goes to the body keeping the register, not to the Financial Intelligence Unit; it is not a suspicious activity report. It is filed by obliged entities such as banks, notaries or tax advisers – the legal entity itself instead fulfils its own reporting duty under section 20 GwG. A typical mistake in family offices: changes in shareholdings are recorded internally but not reported to the transparency register, and the bank notices the discrepancy at the next KYC update.
Relevant in: Germany
Related terms
- Transparency register
- Central register of the beneficial owners of companies and other legal entities.
- Beneficial owner
- The natural person who ultimately owns or controls a company, foundation or trust, or on whose behalf a transaction is carried out.
- Fictitious beneficial owner (Germany)
- Under section 3 of the German Anti-Money Laundering Act, the legal representative, managing partner or partner deemed to be the beneficial owner if no natural person with control can be identified.
Mentioned in these guides
- VwbP: the register of beneficial owners in LiechtensteinWho is entered in Liechtenstein's register of beneficial owners (VwbP), who reports, who has access and what applies when information diverges.