A treasury manager wired more than EUR 50 million to fraudsters posing as his superior over the phone and by messenger within 25 days. The Cologne Labor Court upheld his dismissal and full personal liability – even with D&O insurance in place.

Court of Appeal Berlin (judgment of 11 August 2026 – 5 UKl 1/26): An e-mail address in the legal notice that does not accept messages and refers senders to other contact channels violates § 5(1) no. 2 DDG.

Federal Labour Court (judgment of 4 December 2025 – 2 AZR 51/25): Protection under § 36 HinSchG requires an actual report and a causal link with the detrimental treatment.

Managing directors and board members are not liable for justifiable decisions taken on an adequate information basis – what matters is the documentation of the decision-making basis.

Breaches of duties of care – for instance in a crisis or in the event of compliance violations – trigger personal liability risks. Documentation and early advice provide protection.

The transparency register is becoming an EU-wide harmonised central register; from mid-2027 the control threshold falls to 25 % and the reporting obligations are tightened.

Ten theses on the organisational design of compliance management – and the question of how advisory boards in family businesses are to be involved.