Germany: corporate bank account opening

Obtain the company's registered name, legal form, registration number, registered office and representatives. Use the Handelsregister extract for registered particulars and representation powers. For a GmbH, the filed Gesellschafterliste provides shareholder information; request a newer company-held list if a reported transfer is missing.

Identify beneficial owners

GwG section 3 includes individuals holding more than 25% of capital or voting rights, or exercising comparable control. Trace indirect holdings and obtain agreements where control differs from the registered shareholdings. The senior-management fallback applies only on the statutory conditions, after the required enquiries.

Obtain the relevant Transparenzregister information where required and investigate discrepancies. A beneficial-ownership register entry does not replace the bank's own risk-based identification and verification obligations.

Verify the people acting for the customer and their authority. Check the extract's representation rule and obtain a mandate or power of attorney for account operators whose authority is not registered.

Before the account is used

Under GwG sections 10 and 11, establish the purpose and intended nature of the relationship and complete the required identification and verification. Obtain expected transaction information and supporting funding documents where needed. Apply enhanced measures under section 15 to the relevant higher-risk cases and resolve sanctions findings.

If the section 10 CDD obligations cannot be met, apply the statutory restrictions on establishing or continuing the relationship. Preserve the review and approval evidence, monitor transactions and refresh customer information when material facts change.