UNICORN PRIVATE Sanctions fines in Germany: cases and penalties
Judgments of German courts and decisions of US authorities against German companies.
In short
Published cases on this page: 2. Authorities: 2. Years: 2024 to 2024.
In the United States (OFAC, BIS) and in the United Kingdom (OFSI, since 15 June 2022) civil liability is strict: a company can be fined even if it did not know that the counterparty was sanctioned.
Amounts are shown in the currency of the decision and are never converted.
Good to know
- The judgment of the Higher Regional Court (OLG) Stuttgart is reported in a bulletin of the German Federal Ministry for Economic Affairs (BMWK) of 14 March 2025, where it was not yet final.
Cases
Cases shown: 2 of 2
| Sector | What happened | |||||
|---|---|---|---|---|---|---|
| Aiotec GmbHCivil enforcement action (penalty or settlement) | Germany | Machinery and industrial equipment | OFAC (US Treasury) | $14,550,000 | The company arranged for an Australian polypropylene plant brokered by a US firm to be resold to Iran, with payments through US banks. Official source verified on November 13, 2026 | |
| Swiss holding company not named, and its managerCriminal court judgmentNot final at the time of the bulletin of the German Federal Ministry for Economic Affairs (BMWK) of 14 March 2025. | Germany / Switzerland | Machinery and industrial equipment | OLG Stuttgart | about €3,000,000 (confiscation (holding company)) €2,100,000 (manager, not named, 7 years in prison) |
The manager shipped six dual-use machine tools to a Russian sniper-rifle maker through companies in Switzerland and Lithuania. Official source verified on November 13, 2026 |
Select a column heading to sort the table. Amounts are shown in the currency of the decision and are never converted.
Totals by year and by authority
Sums of the amounts imposed on companies in this list, by currency, never converted. Not included: breaches published without a fine, anti money laundering penalties, confiscations and amounts imposed on individuals. A total marked about or more than includes an amount that the source gives as approximate or as a minimum.
By year
| Year | Cases | Total |
|---|---|---|
| 2024 | 1 | $14,550,000 |
By authority
| Authority | Cases | Total |
|---|---|---|
| OFAC (US Treasury) | 1 | $14,550,000 |
Maximum penalties set by law
Maximums in the law, as verified on the official texts linked:
- European Union, Directive (EU) 2024/1226: each Member State must provide, for companies, maximum fines of no less than 5% of worldwide turnover or €40 million (1% or €8 million for some reporting obligations), and for individuals maximum prison terms of at least 5 years for the main offences above €100,000 and for military or dual-use goods. The offences require intent (serious negligence for military and dual-use goods). Transposition deadline: 20 May 2025. (Official source)
- Germany, Foreign Trade and Payments Act (AWG): fines on companies up to €40 million (§19); prison from 3 months to 5 years, up to 10 years in serious cases (§18). Directive transposed by the law of 5 February 2026. (Official source 1) (Official source 2)
Frequently asked questions
How much can a company be fined for sanctions breaches in Germany?
European Union, Directive (EU) 2024/1226: each Member State must provide, for companies, maximum fines of no less than 5% of worldwide turnover or €40 million (1% or €8 million for some reporting obligations), and for individuals maximum prison terms of at least 5 years for the main offences above €100,000 and for military or dual-use goods. The offences require intent (serious negligence for military and dual-use goods). Transposition deadline: 20 May 2025. Germany, Foreign Trade and Payments Act (AWG): fines on companies up to €40 million (§19); prison from 3 months to 5 years, up to 10 years in serious cases (§18). Directive transposed by the law of 5 February 2026.
Which companies have been fined in cases involving this country?
This page lists 2 published cases. The largest amounts are: Aiotec GmbH (OFAC (US Treasury), December 3, 2024): $14,550,000. The judgment of the Higher Regional Court (OLG) Stuttgart is reported in a bulletin of the German Federal Ministry for Economic Affairs (BMWK) of 14 March 2025, where it was not yet final.
Does a German company have to know that it is breaching sanctions to be punished?
Directive (EU) 2024/1226, which Germany transposed by the law of 5 February 2026, requires criminal offences committed with intent, and for military and dual-use goods also with serious negligence. The penalties are set in sections 18 and 19 of the Foreign Trade and Payments Act (AWG).
Who punishes sanctions breaches in Germany?
Criminal cases are prosecuted by the public prosecutors and decided by the courts, for example the Higher Regional Court (OLG) Stuttgart in the case listed here. US authorities have also acted against German companies.
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List not exhaustive, based on public official sources. Date of the last verification: November 13, 2026.
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