UNICORN PRIVATE Sanctions compliance in Germany: which rules apply and what companies must do
In short
In Germany, EU sanctions regulations apply directly, together with the Foreign Trade and Payments Act (AWG) and its Ordinance (AWV).
BAFA handles export controls and trade licences, while the Deutsche Bundesbank handles financial sanctions.
Companies must not make funds or goods available to listed parties and should screen clients and suppliers regularly.
Applicable rules and competent authorities
EU sanctions regulations are binding in Germany without national transposition. The Foreign Trade and Payments Act (Außenwirtschaftsgesetz, AWG) and the Foreign Trade and Payments Ordinance (AWV) set the national framework and the penalties for breaches.
The Federal Office for Economic Affairs and Export Control (BAFA) is responsible for export controls, including dual use goods, and for licences under trade sanctions. The Deutsche Bundesbank is responsible for financial sanctions, such as asset freezes and licences for payments.
Customs authorities enforce the rules at the border, and the Central Office for Sanctions Enforcement supports the identification of assets of listed persons.
Practical duties for companies
- Do not make funds or economic resources available, directly or indirectly, to persons and entities listed by the EU.
- Screen clients, suppliers, owners and banks against the sanctions lists, also when the lists change.
- Check whether your goods need an export licence from BAFA, including dual use goods.
- Report frozen funds and request licences from the competent authority when required by the EU regulations.
- Keep records of the checks you carried out and of the decisions taken.
Fines and penalties
Statutory maximums we verified on the official texts:
- European Union, Directive 2024/1226: fines on companies of at least 5% of worldwide turnover or €40,000,000, and prison terms of at least 5 years. (source)
- Germany: fines on companies up to €40,000,000. (source)
Maximum amounts set by law, as published by the authorities linked, checked on October 29, 2026.
Official sources
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Frequently asked questions
Who is responsible for financial sanctions in Germany?
The Deutsche Bundesbank is responsible for financial sanctions, such as asset freezes and licences for payments and transfers.
Who issues export licences in Germany?
The Federal Office for Economic Affairs and Export Control (BAFA) issues export licences, including for dual use goods and goods covered by trade sanctions.
Do EU sanctions apply directly to German companies?
Yes. EU sanctions regulations are directly binding in Germany. The AWG and the AWV add the national rules and the penalties.
The program can make mistakes. The final responsibility for compliance stays with your company. Unicorn Intelligence is an information tool. Decisions and legal obligations, including sanctions compliance, due diligence and tender participation, remain with the customer.
Unicorn Intelligence checks your clients and suppliers against the sanctions lists every day.