Global sanctions guide

  1. Does Germany have a sanctions regime in place? 

Yes. However, information on financial sanctions and legal acts are predominantly provided in German. The main legal acts can be retrieved in English as well. Among other sources, the following links can be used:

Außenwirtschaftsverordnung / Foreign Trade and Payments Ordinance

Außenwirtschaftsgesetz / Foreign Trade and Payments Act

The Federal Ministry of Economics and Technology (“BMWi”) in conjunction with Deutsche Bundesbank, the Federal Office of Economics and Export Control (“BAFA”), is responsible for the application of the Foreign Trade and Payments Act, the Foreign Trade and Payments Ordinance and the implementation of financial sanctions regarding the fight against the financing of terrorism.

The export of arms is additionally subject to the War Weapons Control Act and related ordinances. Germany has furthermore signed the Chemical Weapons Convention which has been implemented by the Act on Execution of the Chemical Weapons Convention.

Deutsche Bundesbank administers the implementation of the freezing of funds. BAFA administers the implementation of freezing orders on economic resources and other assets.

  1. Does Germany implement UN sanctions? 


  1. Does Germany implement an autonomous sanctions regime? 

Section 4 of the Foreign Trade and Payments Act allows for the implementation of autonomous regimes. This is done to: (i) guarantee the essential security interests of the state; (ii) prevent a substantial disturbance to foreign relations; (iii) implement decisions of the Council of the EU on economic sanctions in the field of Common Foreign and Security Policy; (iv) implement obligations of the member states of the EU which are provided for in directly applicable legal acts of the EU; (v) implement economic sanctions in the field of Common Foreign and Security Policy; and (vi) implement UNSC resolutions. Usually Germany only implements sanctions which are based on EU-regulations or UN-resolutions, save for sanctions related to the export of arms.

  1. What is the nature of the sanctions regime in Germany? 

The sanctions regime in Germany described at point 3 above is implemented by ordinances. Restrictions or obligations can additionally be imposed by administrative act to avert a danger pertaining in an individual case to material interests of the state. For example, if essential security interests are in danger, if substantial disturbance to the foreign relations has to be expected or if there is a danger to the coverage of vital needs in Germany.

Where no national legislation is implemented, EU regulations can also apply directly.

  1. Does Germany maintain a list of sanctioned individuals and entities? 

No. Germany relies on the EU consolidated list. Specific names can be checked against the EU sanctions list accessible via:

  1. Are there any other lists related to sanctions? 

The BAFA provides:

  1. Does Germany have a licensing or authorization system in place? 

Section 8 of the Foreign Trade and Payment Act provides for the issuing of licences. The Foreign Trade and Payment Act, or any ordinance issued on the basis of it, may state that a license is required for a transaction or action.

  1. What are the consequences for a breach of sanctions in Germany? 

Section 17 of the Foreign Trade and Payments Act states that a prison sentence of between one and ten years can be imposed on anyone who violates an ordinance which serves to implement a UN or EU sanction if this violation is related to specific goods listed in part 1 of the export list.

Section 18 of the Foreign Trade and Payments Acts states that a prison sentence of between three months and five years can be imposed on anyone who violates other provisions of the Foreign Trade and Payments Act or the Foreign Trade and Payments Ordinance. In specific cases, only fines may be charged.

  1. Who are the relevant regulators in Germany and what are their contact details?

Competent authority for funds, financing and financial assistance:

Deutsche Bundesbank
Servicezentrum Finanzsanktionen
D-80281 München

T: (+49) 89 2889 3800
F: (+49) 69 709097 3800

Competent authority for goods, economic resources, technical assistance, brokering services, services and investments:

Bundesamt für Wirtschaft und Ausfuhrkontrolle (BAFA)
Frankfurter Strasse 29 – 35
D-65760 Eschborn

T: (+49) 61 96 908 0
F: (+49) 61 96 908 800


Contributor law firm

Tatjana Tscherevko, Eversheds Sutherland (Germany) LLP, Brienner Straße 12, 80333 München