BaFin fines Brown Capital Management €187,500 for WpHG breaches
BaFin imposed administrative fines totalling €187,500 on Brown Capital Management LLC for failing to submit voting rights notifications on time under the WpHG.
BaFin fined US-based Brown Capital Management for late voting rights notifications, underscoring active enforcement of German transparency obligations against foreign asset managers. The action highlights that WpHG disclosure duties apply irrespective of domicile.
Reinforces enforcement risk around major shareholding disclosures for cross-border asset managers and custodians.
Action Required
Review major shareholding notification processes and calendars to ensure timely WpHG disclosure compliance.
Concrete enforcement outcome relevant to disclosure compliance programmes at institutional investors.
Reassess controls over WpHG voting rights notifications, including threshold monitoring, workflow ownership and cross-border escalation, to mitigate similar fine exposure.
“On 10 July 2026 BaFin imposed administrative fines totalling €187,500 on Brown Capital Management LLC for failing to submit voting rights notifications within the prescribed period under the WpHG.”
Published: 2026-07-22