Step by step towards absolute transparency – the asset register

The plans to centralise assets and their owners are not new, as the EU has been pursuing this plan since 2021. Now the time may soon come and a corresponding asset register may be introduced over the course of next year. Critics fear that a control and monitoring system is to be set up under the pretext of combating money laundering and terrorist financing, which will make all financial transactions and assets of citizens accessible to the authorities at the touch of a button and achieve not only transparency, but also a virtual transparency of financial circumstances. 

All assets over 200,000 euros, such as real estate, bank accounts, securities, foreign assets, crypto assets, vehicles, yachts and possibly also works of art or precious metals, are to be included in the register. It is to be feared that the limit of 200,000 euros is not “set in stone”, so that a reduction seems possible, if not probable. 

 

It is also unclear whether the detailed register can be used for other purposes in addition to money laundering prevention, e.g. for wealth redistribution and tax increases (wealth tax) or the Equalisation of Burdens Act.

In addition to the authorities, “persons with a legitimate interest, such as journalists, reporters, other media, civil society organisations and higher education institutions” are also to be granted access, just as with the transparency register. The information will be made available digitally and in English and at least one other official EU language. As with the transparency register, the information must be up to date. Failure to provide the data could be sanctionable, whereby at least in Germany it can be assumed that the level of sanctions will be similar to other breaches of the obligation to register in the transparency register and that the breach will probably also be publicised on the supervisory authority's website (principle of naming and shaming).

In any case, the compliance requirements for companies and entrepreneurs will increase, as it already requires a certain amount of personnel and organisation to provide the data for the individual registers, keep it up to date and avoid contradictory statements. 

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After all, in view of the almost inflationary introduction of registers, one cannot help but get the impression that the individual is being screened bit by bit to the point of becoming a transparent citizen – at the expense of privacy. But this is the price that will have to be paid at the end of the day for a more efficient fight against money laundering and terrorist financing.​