Sanctions and Export Controls in Germany

Sanctions Imposed on Russian-Occupied Areas of Ukraine

Germany imposes comprehensive sanctions on the following regions:

Crimea
Sevastopol
Donetsk
Kherson
Luhansk
Zaporizhzhia

These sanctions are in place to address the situation in Russia-occupied areas of Ukraine.

Sanctions Imposed on Other Non-EU Countries

Germany also applies sanctions to various non-EU countries, including:

Armenia
Azerbaijan
Belarus
Burundi
China
Democratic Republic of the Congo
Guinea
Iran
Iraq
Lebanon
Libya
Mali
Moldova
Myanmar (Burma)
Nicaragua
North Korea
Russia
Somalia
South Sudan
Sudan
Syria
Tunisia
Turkey
Ukraine (non-government controlled areas)
Venezuela
Yemen
Zimbabwe

These sanctions aim to promote stability, democracy, and human rights in these countries.

Lifting Sanctions

The process for lifting sanctions in Germany is as follows:

A unanimous decision by the Council must be made to revoke sanctions.
EU regulations often contain an end date so that instead of a uniform decision to lift them, a uniform decision to maintain the sanctions will usually be required every six months.

Export Control Regime

Germany has a distinct export control regime for dual-use items governed by Regulation (EU) 2021/821 (“Dual-Use Regulation”). This includes:

Assessment criteria
Types of authorizations
Controls on brokering and technical assistance
Compliance measures for exporters

This regime aims to prevent the proliferation of weapons of mass destruction and promote international security.

Blocking Statutes

Germany enforces the EU Blocking Statute, which prohibits compliance with certain US sanctions on:

Iran
Cuba
Libya

The GDPR can also act as a “blocking statute” in some cases by prohibiting transfers to non-EEA countries or processing personal data pursuant to obligations outside of EU or EU Member State law.