Sanctions screening for small companies in Germany
Updated · Rotomal
EU sanctions regulations forbid every company in the EU from making funds or economic resources available, directly or indirectly, to listed persons and entities; the law leaves open how you ensure this. Intentional breaches carry three months to five years in prison under § 18 AWG, negligent ones are administrative offences with fines up to €500,000 under § 19 AWG. The usual approach is a documented screening of all business partners, before the first deal and regularly afterwards, because the lists change constantly.
Which lists exist
| List | Publisher | Access |
|---|---|---|
| EU consolidated financial sanctions list | European Commission (DG FISMA) | Open data; the EU Official Journal is binding |
| UK Sanctions List | UK government | CSV, XML, ODS and online search; the only UK list since 28 January 2026 |
| US Consolidated Screening List | US Departments of Commerce, State and Treasury | Free search, CSV, JSON and API |
| finanz-sanktionsliste.de | German federal and state justice portal | Search based on the EU list, aimed mainly at the judiciary |
The EU itself notes that its consolidated list may lag behind the Official Journal. On 7 November 2026, finanz-sanktionsliste.de showed 23 October 2026 as its data date.
Penalties for breaches
| Provision | Offence | Range |
|---|---|---|
| § 18(1) AWG | Intentional breach of making-available or disposal bans | 3 months to 5 years in prison, attempts punishable |
| § 19(1) and (6) AWG | Negligent breach | Fine up to €500,000 |
| § 19(7) and (8) AWG | Corporate fine (§ 30 OWiG) for an intentional offence under § 18(1) or a supervisory failure (§ 130 OWiG) | Up to €40 million |
A lean procedure in five steps
- Keep all customers and suppliers in one list with name, address and country.
- Screen against the EU list before the first deal, and against UK and US lists where relevant.
- Rescreen the whole base regularly, because listings are added constantly.
- Review possible matches using date of birth, registration number, country and address, and record the reason.
- On a real match, pause the deal and involve the competent authority or a lawyer; in Germany the Deutsche Bundesbank handles financial sanctions.
If you would rather hand it off
Listenwache does the screening, review and log from €39 a month, and the first screening of 100 partners costs €9. It does not replace your own responsibility and is not legal advice; clarify your specific duties with the competent authority or a lawyer.
Questions
Is one check when the contract is signed enough?
Usually not. The lists are updated constantly and a partner can be listed after you sign. That is why companies rescreen their base regularly.
Is the OFSI list still valid?
No. The OFSI Consolidated List closed on 28 January 2026 and is no longer updated. The UK Sanctions List is the reference since then.
Sources
- Gesetze im Internet: § 18 AWG Source: gesetze-im-internet.de
- Gesetze im Internet: § 19 AWG Source: gesetze-im-internet.de
- IHK Frankfurt am Main: financial sanctions Source: frankfurt-main.ihk.de
- data.europa.eu: EU consolidated financial sanctions list Source: data.europa.eu
- GOV.UK: The UK Sanctions List Source: gov.uk
- trade.gov: Consolidated Screening List Source: trade.gov
- Justice portal: finanz-sanktionsliste.de Source: finanz-sanktionsliste.de