Germany’s Sanctions and Export Control Regime

Areas under Russian Occupation Subject to Comprehensive Sanctions

It appears that certain areas in Ukraine are subject to comprehensive sanctions due to their occupation by Russia. Specifically:

• Crimea
• Sevastopol
• Parts of the Donetsk, Kherson, Luhansk, and Zaporizhzhia oblasts

These regions are currently under comprehensive sanctions.

Imposing or Revoking Sanctions: A Unanimous Decision

The process for imposing or revoking sanctions in Germany involves a unanimous decision by the Council. This applies equally to both the imposition and revocation of sanctions.

Separate Export Control Regime: Dual-Use Regulation

Germany has a distinct export control regime governed by Regulation (EU) 2021/821, also known as the Dual-Use Regulation. This regulation includes rules for:

• Export control
• Common EU lists
• End-use controls
• Provisions on administrative cooperation

Blocking Statute: Enforcing Compliance with EU Sanctions

Germany enforces the EU Blocking Statute, which prohibits compliance with certain U.S. sanctions on countries such as Iran and Cuba.

This summary aims to provide an overview of Germany’s sanctions and export control regime. If you have any further questions or need clarification on specific points, feel free to ask!