🇩🇪Germany

Mangelhaftes Treasury Management und Liquiditätskontrolle bei Treuhandkonten – fehlende Echtzeit-Transparenz

Updated: Feb 20261 verified sources

Definition

The new § 17 ZAG regime requires separate accounts for client funds, with explicit exclusion from PI/EMI creditor claims. However, firms managing multiple client trusts must reconcile: (1) incoming client payments to firm bank account, (2) rapid transfer to segregated trust account, (3) fund outflows for estate administration costs, (4) investment/reinvestment of client funds. Manual processes create timing gaps where fund location is ambiguous. Without automated reconciliation, treasury staff cannot reliably answer: 'Are these funds segregated yet? Can we use this cash for operations?' Delayed cash position reports (often generated weekly or monthly) mean decision-makers lack real-time fund visibility, risking erroneous fund allocation or duplicate spending.

Key Findings

Financial Impact: €20,000–€150,000 annually in: (1) reconciliation labor (50–200 hours/year at €100–150/hour = €5,000–€30,000), (2) delayed investment opportunity cost (2–5% of AUM if cash sits undeployed due to reconciliation uncertainty = €10,000–€100,000+ for mid-size AUM), (3) interest expense from unintended overdrafts or temporary bridge financing (1–3% on average float balance).
Frequency: Continuous; affects every fund transaction; decision impact: weekly or monthly treasury reviews.
Root Cause: Lack of integrated fund management system that auto-syncs firm bank account, client payment channels (Überweisung, SEPA), and segregated trust accounts in real-time. Manual bank reconciliation statements (often delayed 1–3 days). No API integration between accounting software and bank settlement systems.

Why This Matters

This pain point represents a significant opportunity for B2B solutions targeting Trusts and Estates.

Affected Stakeholders

Treasury Managers, Finance Directors, Trust Administrators, Cash Accountants, Risk Officers

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Financial Impact

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Current Workarounds

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Methodology & Sources

Data collected via OSINT from regulatory filings, industry audits, and verified case studies.

Evidence Sources:

https://financialregulation.linklaters.com/post/102k08d/new-german-rules-on-safeguarding-accounts-what-psps-need-to-know

Related Business Risks

Verbotswidriger Umgang mit Kundengeldkonten gemäß ZAG § 17 – Verwahrungsrisiken bei Treuhandkonten

€5,000–€50,000 per BaFin audit finding for fund segregation violations; total client fund loss if insolvency occurs due to commingling (range: €100,000–€10M+ depending on AUM). Typical remediation cost: €20,000–€100,000 in legal/compliance consulting.

Erbschaftsteuer- und Schenkungsteuerrisiken bei unsachgemäßer Treuhandstruktur

€10,000–€100,000+ per trust in unexpected tax liabilities; gift tax: 19–30% on transferred assets (depending on relationship and exemption use); inheritance tax: 7–30% on estate value (depending on tax class); CFC tax: up to 26.375% on deemed distributions. Typical professional remediation: €5,000–€25,000 per trust in tax advisory + amended returns.

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