Embargoes and sanctions are political tools used to restrict the freedom of foreign trade with certain countries. In addition to personal sanctions (terrorist lists), there are extensive international restrictions on the import and export of goods and on the services, finance and insurance sectors in place against various countries. Violations of embargoes are covered by administrative fines or criminal penalties and are prosecuted by the competent authorities. Businesses risk high administrative fines and personally liable employees may face severe penalties.
Violations of such restrictions may also have a negative impact on a company’s business because there is a risk of negative media coverage and withdrawal of customs simplifications (e.g. loss of AEO status or authorised consignee status).
Export bans and authorisation requirements
Practical implementation of terrorist and sanction lists
Prohibitions on the performance of contracts with, and prohibitions of making funds or economic resources available to, listed firms or individuals
Restrictions on investments, insurance, payments and financing services
Advice regarding the impact on existing contracts (“provisions governing existing contracts”)
Proceedings before the German Federal Office for Economic Affairs and Export Control (BAFA), the German Federal Bank (Bundesbank) and customs
Compliance
Legal consequences of violations (criminal offences, administrative offences)
Sanctions against Russia and the embargo against Iran are currently the economic sanctions with the most relevance for German companies. Personal sanctions and sanctions on particular goods and services against these two countries are added and updated on an ongoing basis. However, this also applies to sanctions against other countries. Our lawyers advise clients on how to protect themselves against these dynamic restrictions with compliance measures and how to limit liability risks of the persons involved and of their company, but also on how to take advantage of possibilities that continue to exist, and how to do so in compliance with applicable laws and regulations.
This consolidated version of the Regulation is intended to serve as a work aid and overview of the current status of the Russia embargo.
