Germany Releases Draft 2nd Sanctions Enforcement Act
Germany released the draft Sanctions Enforcement Act II, which looks to make structural improvements to its sanctions and anti-money laundering enforcement efforts, according to an unofficial translation. The first installment of the legislation passed in May. The new bill would create a Central Office for the Enforcement of Sanctions to enforce EU sanctions in Germany, provide administrative procedures to identify funds or economic resources owned or controlled by sanctioned individuals or entities, and let the Central Office appoint a special representative to monitor entities' sanctions compliance.
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The bill would also link around 530 land registries to the transparency register; require foreign entities to report existing German property to the transparency register; require entities to justify why a "fictitious beneficial owner" is needed where appropriate; ban the use of cash, cryptocurrency and "commodities" to buy real estate; make U.N. listings directly applicable; and extend certain financial supervision regulations to those included on the EU sanctions list.