In June 2017, the law implementing the Fourth EU Money Laundering Directive also revised section 40 of the German Limited Liability Companies Act (GmbHG), requiring German limited liability companies’ lists of shareholders (Gesellschafterliste) to contain information on the percentage participation of each shareholder. In addition, section 40 paragraph 4 of the GmbHG authorizes the issuance of future regulations to stipulate further requirements for lists of shareholders. The German Federal Ministry of Justice and Consumer Protection has made use of this authorization to issue the Regulation on the Structure of the List of Shareholders (Gesellschafterlistenverordnung-GesLV). The regulation entered into force on July 1, 2018, and resolves a number of previously unanswered questions. The following is a summary of the most important points.
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