Global sanctions guide

  1. Does Germany have a sanctions regime in place? 


  1. Does Germany implement UN sanctions? 

Yes. Germany is a member of the European Union, which implements UN sanctions in all member states by way of directly effective regulations.

  1. Does Germany implement an autonomous sanctions regime? 

Yes. Section 4 of the Foreign Trade and Payments Act 2013 (“the Act”) allows Germany to implement autonomous sanctions. Ordinarily, Germany only implements autonomous sanctions in relation to arms exports.

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

Germany follows the restrictive measures laid down by the UN, the EU and other international organisations which are binding on Germany, as well as measures introduced autonomously.

International sanctions which are not directly effective in Germany are implemented by ordinances. As well, administrative acts may be used to impose restrictions or obligations to avert a danger to the material interests of the state, for example following a substantial change in foreign relations with another country.

Lastly, the export of arms is controlled by the War Weapons Control Act 1961 (as amended), the Act on the Execution of the Chemical Weapons Convention 1994, and related ordinances.

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

No. Germany relies on UN and EU sanctions lists.

  1. Are there any other lists related to sanctions? 

The Deutsche Bundesbank provides a list of countries subject to financial sanctions: which can be found here.

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

Yes. Licences are required in certain circumstances. A licence must be issued where the proposed transaction or act will not endanger the purpose of the licence requirement or will do so only to a minor degree (Section 8(1) of the Act). As well, ordinances issued on the basis of the Act can require the issuing of certificates (Section 9 of the Act).

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

The consequence for a breach of UN or EU sanctions is imprisonment between 1 and 10 years (Section 17(1) of the Act).

The consequence for a breach of any other provisions of the Act or the Foreign Trade and Payments Ordinance is imprisonment between 3 months and 5 years (Section 18(1) of the Act).

In certain cases only a fine may be charged (Sections 17 and 18 of the Act).

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

The Federal Ministry of Economics and Energy is responsible for the application of the Act, the Foreign Trade and Payments Ordinance and the implementation of financial sanctions relating to terrorism.

BMWi Berlin
Scharnhorststraße 34-37
10115 Berlin

T: (+49) 30 18 615 9
F: (+49) 30 18 615 7010

The Deutsche Bundesbank is responsible for the freezing of funds, financing and financial assistance.

Deustche Bundesbank

The Federal Office of Economic Affairs and Export Control (known as “BAFA”) is responsible for export controls, licences and technical assistance.

Frankfurter Straße 29-35
65760 Eschborn

T: (+49) 6196 908 0
F: (+49) 61 96 908 800


Contributor law firm

Thomas Tüllmann, Eversheds Deutschland LLP, Alsterufer 20, Hamburg, 20354, Germany

T: (+49) 40 80 80 94 10
F: (+49) 40 80 80 94 199