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Would you like to rent a safe deposit box for business purposes?

Would you like to rent a safe deposit box for business purposes? This is possible at CitySafes, but in that case we need some additional information from you before we can conclude a contract with you. According to the Money Laundering and Terrorist Financing Act (Prevention Act), as a representative of a company we are obliged to ask you some additional questions. The answers to these questions will help us to reduce the likelihood of doing business with criminal organisations that misuse our services for illegal activities. Through these questions, we would like to gain insight into the following topics:

  1. Your company’s beneficial owner(s) (UBO).
  2. Your company’s business activities and the purpose of using your safe deposit box to support those activities.

Below we explain what is meant by these questions and how you can answer them. If you have any questions about these topics or how to answer them, please email us at

Beneficial owners (UBO)

With a UBO statement (ultimate beneficial owner), you give us insight into the individuals who have a participation of ≤25 % in your company. This participation can be in the form of shares or in the form of voting rights to dismiss or appoint the executive board or supervisory board. Depending on the organisational form, these can be different individuals.

What do you fill in if your organision is

a one-man limited company or you are self-employed? You yourself are 100% interested. Fill in your personal data, sign the declaration and send it back to us.

a general partnership or limited partnership? There are several interested parties. Enter the personal details of all persons with a share of 25 % or more on the statement. Have the statement signed by at least one of the shareholders/managing directors and return the statement to us.

a private company, a public limited company, or cooperative association? Enter the personal details of all persons with a share of 25% or more on the statement. Sign the statement and return it to us. The signature of a beneficial owner is sufficient.

an association or foundation? Does your association or foundation have no ultimate beneficial owners with a shareholding of 25% or more, but only directors? Then you can indicate these directors as the ultimate beneficial owners. The signature of one of the directors will be sufficient.

a government institution or regulated financial institution? You do not have to declare the beneficial owner(s). The organisation is supervised by the government or the German regulatory authorities. Sign the declaration and return it to us.


The name of the organisation is never the ultimate beneficial owner, these are always natural persons in your organisation.


Determine the stakeholder percentage

We ask you to enter the percentage of direct and indirect interest. Direct interest means that a natural person is a shareholder of your company or has the right to vote to appoint or remove the board of directors or supervisory body of your company. Indirect interest means that a natural person has such an interest in your company through another organisation. Below we give some examples:


Example 1: Your organisation has three stakeholders. Two beneficial owners own 40 % of the shares as natural person. Person three holds 20% of the shares as a natural person. Person three is not a UBO because his percentage share is below the 25% threshold. You only enter the data of person one and two on the statement because both have a direct shareholding of more than 25 %.
Example 2: Your organisation is part of a holding company or foundation. The holding company owns 100% (of the assets) of your organisation. Is your organisation part of several holding companies or foundations? Then we look for the natural persons with interests in the ‘highest’ organisation, i.e. the ‘top of the organisation tree’. In this example, both stakeholders have an indirect shareholding of 50 %.
Example 3: Two foundations or holding companies each own 50% of the shares in your company. Two beneficial owners of Holding X each own 50 % of the shares of Holding X. The two persons then both have a 25 % shareholding in your company.
In Holding Y, person one owns 75% of the shares of Holding Y and person two owns 25%. This means that person one holding Y has 37.5% (50% × 75% = 37.5%) indirect interest in your company. Person two of holding Y also has an indirect interest of 12.5% in your company. This is below the 25% threshold. You therefore only note persons one and two of Holding X and person one of Holding Y on the statement.

Business activities and purpose of the vault

In the “Statement of Activities” you describe the activities of your company and how you will use the locker you wish to rent to support these activities. We give some examples below:

You are a notary: The work of my office consists of preparing notarial deeds, such as mortgage deeds and the notarisation of wills. If our clients request it, we preserve a copy of the deed(s) for the client. These copies are kept securely in a safe deposit box at CitySafes.

You are the owner of a car dealership: We buy and sell cars. To prevent the cars in our possession from being stolen, we keep the associated vehicle documents in a safe deposit box at CitySafes.

You trade in valuable coins: We buy valuable coins from a network of coin dealers and sell them to private individuals. As we have been burgled in the past, we do not want to keep the coins on the premises and instead store them in a safe deposit box at CitySafes.

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