Sanctions Screening for German Notaries and Real Estate Agents

§ 3 Abs. 3 GwGMeldV-Immobilien requires reporting of every transaction in which a party, an acting person or a beneficial owner falls under an EU sanctions measure. We deliver the verifiable evidence — audit-grade, refreshed every day.

Early Access. Sanctions lists may be amended by the issuing authorities at any time.

Sanctions screening per § 3 Abs. 3 GwGMeldV-Immobilien · EU hosting (Germany) · Audit-grade trail

What the regulation requires

§ 3 Abs. 3 GwGMeldV-Immobilien — Regulation of 20 August 2020 (BGBl. I p. 1965).

German notaries (§ 2 Abs. 1 Nr. 10 GwG) and real estate agents (§ 2 Abs. 1 Nr. 14 GwG) are obliged entities under the Geldwäschegesetz (German AML Act). For real estate transactions with a sanctions nexus, the reporting duty is concretised:

In an acquisition, facts must always be reported within the meaning of § 43 (1) of the Geldwäschegesetz if a party to the acquisition, a person acting on their behalf, or a beneficial owner is subject to a sanctions measure of the European Union applicable within the scope of the Geldwäschegesetz. § 3 Abs. 3 GwGMeldV-Immobilien (translation; the German text is authoritative)

In practice this means: anyone who fails to screen a party, an acting person or a beneficial owner against the applicable EU sanctions lists cannot fulfil the reporting duty under § 43 GwG. The report itself goes to the FIU (Financial Intelligence Unit, German Customs). Breaches expose obliged entities to fines of up to EUR 5 million or 10 % of annual turnover under § 56 GwG.

What 123sanctions delivers

The evidence the regulation requires — as a verifiable document.

Full EU sanctions coverage: EU-CSL (consolidated list of all EU sanctions measures) plus UN, OFAC, UK OFSI, Swiss SECO. Refreshed every night, with the source date attached to every match.
Match documentation for the file: Every screening produces an audit-grade record — who was screened, when, against which lists in which version, with the resulting assessment. Drop straight into the transaction file.
Beneficial owner — not just the buyer: The regulation requires checking all three categories of person. 123sanctions accepts multiple persons per transaction and handles natural and legal persons alike.
Self-monitoring of detection rate: We test our own scoring chain every night against all lists with mutations — and publish the results. You see the detection quality before you run a check.
EU hosting in Germany: Data does not leave the EU. AVV-ready, GDPR-compliant, AES-256-GCM encrypted at rest.

The platform does not replace the legal assessment of a hit — that remains with the notary or agent. It delivers the verifiable evidence: screening was performed, against these lists, in this version, with this outcome.

How it fits the workflow

Three steps, one report — fits the preparation phase before notarisation.

Enter the persons: parties, persons acting on their behalf, beneficial owners. Manually or by CSV from the client master record.
Run the screening: matching against all active EU sanctions measures plus UN/OFAC/UK/SECO. The assessment accounts for spelling variants, transliterations and alternative name orders.
Report into the file: PDF with screening date, list version numbers and per-person assessment. Citable to supervisory authorities and the FIU.

Sanctions screening — built for audits.

Early Access is free: all official sources, the full screening process and audit-grade exports.