Stand: April 2026. German authorities have initiated more than 1,400 preliminary investigations into potential EU sanctions violations — and the number continues to rise. For companies with operations, subsidiaries or supply chains touching sanctioned jurisdictions, the risk of criminal and administrative exposure is substantial.
What Is Germany’s Sanctions Enforcement Framework?
Germany enforces sanctions imposed by the United Nations, the European Union and — in exceptional cases — German national authorities. EU sanctions regulations apply directly in Germany without the need for national legislation, making the EU Russia sanctions packages immediately binding on all companies operating in Germany.
Multiple authorities share responsibility for enforcement:
- BAFA (Federal Office for Economic Affairs and Export Control): handles prohibitions and licensing requirements for goods and non-financial services
- The Customs Administration: supports BAFA in the enforcement of export controls
- The Central Office for Sanctions Enforcement (established January 2023): coordinates and monitors compliance with EU-mandated asset freezes and transfer bans
- The Service Centre for Financial Sanctions of the German Federal Bank: responsible for implementing financial sanctions, with banks and insurers as key private-sector actors
What Are the Penalties for Sanctions Violations?
Violations of applicable sanctions may result in both administrative fines and criminal penalties, including custodial sentences. In recent years, enforcement has intensified significantly, particularly in connection with the Russia-Ukraine conflict. The most recent EU Russia sanctions package was published on 19 July 2025.
A key focus for German authorities are cases in which corporations are suspected of having circumvented sanctions through third-country structures — routing goods or funds via intermediaries in countries not subject to EU restrictions.
Does Voluntary Disclosure Help?
In specific circumstances, voluntary self-disclosure may exempt a company from administrative fines. However, self-disclosure does not automatically preclude criminal liability in cases of intentional or severe violations. Early coordination with experienced defence counsel is essential before any disclosure is made.
International Cooperation Is Intensifying
German enforcement does not operate in isolation. Coordination at the G7 level takes place through the Task Force on Russian Elites, Proxies and Oligarchs (REPO) and the Enforcement Coordination Mechanism. At EU level, the Freeze and Seize Task Force coordinates enforcement across Member States. In April 2025, the fifth Sanctions Coordinators Forum brought together representatives from all EU Member States plus the UK, US, Japan, South Korea, Canada, Australia and others.
For companies, this means that a sanctions investigation in Germany may be closely coordinated with — or even triggered by — authorities in other jurisdictions.
Key Risk Areas for Companies in 2026
- Exports or re-exports of dual-use goods to Russia via third countries
- Financial transactions involving sanctioned individuals or entities, including indirect exposures
- Energy-related business activities connected to Russian oil
- Iranian sanctions: as of 19 July 2025, the EU has also imposed new sanctions on Iran, covering 232 individuals and 44 entities
