Sanctions Law

Sanctions Law Advisory Services

We advise companies on all EU sanctions and embargoes, as well as on the relevant national implementing regulations. Given the current geopolitical situation, our current focus is on advising clients on the sanctions packages in connection with the Russia-Ukraine conflict. A further area of focus is EU sanctions regulations, such as those directed against Iran or Syria.

In the area of sanctions and embargoes, our range of services includes in particular:

Export prohibitions and licensing requirements
Screening and handling of terrorism and sanctions lists
Fulfilment and supply prohibitions vis-à-vis listed persons and entities
Investment, insurance, payment, and financing restrictions
Handling of existing contracts ("grandfathering provisions")
Administrative proceedings before the Federal Office for Economic Affairs and Export Control (BAFA), the Bundesbank, and the customs authorities
Legal consequences of violations

Decades of
Experience

Over 100 years of combined experience providing sound and reliable legal advice.

Interdisciplinary
Approach

Legal expertise, technical know-how and experienced project management in customs and foreign trade law.

Multiple
Awards

Recognized excellence with repeatedly awarded consulting quality at national and international level.

FAQs - Frequently Asked Questions

Sanctions law encompasses measures imposed by states or supranational bodies (e.g. the EU, UN, USA) that introduce economic or diplomatic restrictions against states, organisations, or individuals in order to enforce specific political objectives. It serves the purposes of maintaining peace, combating terrorism, and enforcing human rights. The key areas include:

1. Economic sanctions: Trade restrictions, investment prohibitions, import and export restrictions.

2. Financial sanctions: Asset freezes, transaction prohibitions, asset release obligations.

3. Embargoes: Comprehensive trade and economic blockades (e.g. arms embargoes).

4. Travel restrictions and visa bans.

5. Sectoral sanctions: Targeted restrictions on specific economic sectors (e.g. energy, banking).

German companies are affected in particular by EU sanctions as well as by extraterritorially applicable U.S. sanctions (e.g. OFAC).
The following sanctions regimes are of particular importance for German companies:

1. EU sanctions: Binding on all member states; currently in place against, among others, Russia, Belarus, Iran, Syria, and certain terrorist organisations.

2. U.S. sanctions: Particularly relevant where U.S. business partners, U.S.-origin goods, or dollar-denominated transactions are involved (e.g. OFAC listings).

3. UN sanctions: Implemented through EU regulations.

4. German national sanctions (e.g. Foreign Trade and Payments Regulation, AWV).

Key embargoes concern, among other things, defence goods, dual-use goods, technology transfers, as well as sanctioned countries and individuals. Ongoing monitoring is essential, as sanctions lists change frequently.
1. Screening of business partners: Regular checks of customers, suppliers, and contractual partners against current sanctions lists (e.g. EU listings, OFAC SDN List).

2. Goods review: Checking whether exported/imported goods fall under embargoes or sectoral restrictions (e.g. dual-use goods, defence goods).

3. Transaction analysis: Reviewing payment flows and trade routes for points of contact with sanctioned countries or persons.

4. Use of screening tools and databases (e.g. BAFA listings, EU sanctions map, commercial compliance software).

5. Internal policies: Implementation of a compliance management system (CMS) with regular training and risk assessments.

In cases of doubt, a legal assessment should be obtained from a law firm specialising in sanctions law.
Yes, legal advice is strongly recommended in the following situations:

1. In cases of suspected violations: Immediate review, notification, and damage limitation are critical.

2. Prior to contact with authorities: e.g. BAFA, customs, the public prosecutor's office, or EU/U.S. authorities.

3. For planned transactions involving high-risk countries: Prior assessment of sanctions compliance.

4. Following the entry into force of new sanctions: Adaptation of internal compliance processes.

Sanctions violations can lead to severe penalties (fines, custodial sentences, reputational damage), and CREYDT.LAW can provide you with first-class, legally sound advice in this regard.

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